Animal rights the interests of the worse off more important than those of the better off. Another approach, virtue ethics, holds that in considering how to act we should consider the character of the actor, and what kind of moral agents we should be. Rosalind Hursthouse has suggested an approach to animal rights based on virtue ethics. Mark Rowlands has proposed a contractarian approach. Nussbaum (2004) writes that utilitarianism, starting with Jeremy Bentham and John Stuart Mill, has contributed more to the recognition of the moral status of animals than any other ethical theory. The utilitarian philosopher most associated with animal rights
Jeremy Bentham the felicific calculus, Bentham proposed a classification of 12 pains and 14 pleasures, by which we might test the "happiness factor" of any action. Nonetheless, it should not be overlooked that Bentham's "hedonistic" theory (a term from J.J.C. Smart), unlike Mill's, is often criticized for lacking a principle of fairness embodied in a conception of justice. In "Bentham and the Common Law Tradition", Gerald J. Postema states: "No moral concept suffers more at Bentham's hand than the concept of justice. There is no sustained, mature analysis of the notion..." Thus, some critics object, it would be acceptable to torture one