The tribunal decided that secondary heads did not face more "demanding" pupils. But this was "a close call", because of "the paucity of evidence from the primary sector".
The tribunal was swayed by the evidence of the then head of Mallaig Secondary, a 160-pupil school. Forbes Jackson said behavioural difficulties were not a major issue. The tribunal ruled: "Whilst there may generally be a higher incidence of problems in the secondary sector, this was not an indication that the headteachers were more involved to a significant extent, justifying a higher salary".