In Hoyland v Asda Stores Ltd the Court of Session upheld the EAT's decision that a pro rata reduction of a bonus to reflect an employee's absence on ordinary maternity leave was not sex discrimination. Although the bonus was expressed to be "discretionary", the Court of Session found that it was regulated by the contract of employment. As such, it fell within section 6(6) of the Sex Discrimination Act 1976 (SDA) which excludes claims relating to pay from the scope of the SDA.