In theory, misfeasance is distinct from nonfeasance. However, an action in tort ("ex delicto") will lie only in misfeasance or malfeasance. They alleged both negligence and misfeasance under s 212 of the Insolvency Act 1986. Misfeasance in public office is considered to be a special kind of public law tort. The liquidators brought proceedings against the directors of the company for misfeasance and wrongful trading. Misfeasance, by contrast, is some affirmative act that, though legal, causes harm. The director was accused of committing a misfeasance. The NFL found that Payton and Loomis' misfeasance amounted to "conduct detrimental" to the league. It concerns the right to vote and misfeasance of a public officer. It has therefore been perceived as a way to combat misfeasance in public officials. Furthermore, payments to two other companies, IATA and ABTA, showed misfeasance. The ruling clarified that there are two types of misfeasance in public office.