 In "Paper Reclaim Ltd v Aotearoa International"  it was held that exemplary damages are not to be awarded in actions for breach of contract but the Court left open the possibility that exemplary damages might be available where the breach of contract is a tort.More recently in "Couch v Attorney-General" the New Zealand Supreme Court barred exemplary damages for cases of negligence unless the defendant acts intentionally or with subjective recklessness.Punitive damages can also be awarded for equitable wrongs.