The Court will, in certain cases, award an additional element for loss of congenial employment. This area was considered in the case of Morris v Johnson Mathey & Co Ltd in 1967 in which the Judge stated:

"The joy of the craftsman in his craft is beyond price. But the Court has to give some monetary value to the loss of craft. The Court should give consideration to the fact that the craftsman had to replace his craft with humdrum work."

In Appleton v Medhat Mohammed el Sasty (2007) the footballer had been a professional footballer when he suffered an injury. The surgeon negligently treated the footballer who was unable to continue to play professional football. When assessing his damages, the footballer was awarded an additional £25,000 for the loss of, what many people would consider to be a dream job. This award is at the highest end of the bracket, however this additional award is becoming more common and there are many examples of firemen and police who claim under this bracket.