English law recognised the awarding of exemplary damages, that is, damages whose object was to punish or deter and which were distinct from aggravating damages (whereby the motives and conduct of defendant aggravating the injury to plaintiff would be taken into account in assessing compensatory damages); and there were two categories of cases in which an award of exemplary damages could serve a useful purpose, viz, in the case of oppressive, arbitrary or unconstitutional action by the servants of the government, and in the case where defendant's conduct has been calculated by him to make a profit for himself, which might well exceed the compensation payable to plaintiff.