What is the difference between a plaintiff's contract and a primary right?

Even if we were to examine the issue through the lens of primary rights theory, however, the outcome would be the same. Vera mistakes her legal theories of recovery for primary rights. A primary right "is simply the plaintiff's right to be free from the particular injury suffered. [Citation.] It must therefore be distinguished from the legal theory on which liability for that injury is premised: Even where there are multiple legal theories upon which recovery might be predicated, one injury gives rise to only one claim for relief. [Citation.] The primary right must also be distinguished from the remedy sought: The violation of one primary right constitutes a single cause of action, though it may entitle the injured party to many forms of relief, and the relief is not to be confounded with the cause of action, one not being determinative of the other. " ( Crowley v. Katleman , supra , 8 Cal.4th at pp. 681682, 34 Cal.Rptr.2d 386, 881 P.2d 1083.) The particular injury Vera suffered, as alleged in her complaint, was buying a property worth less than she believed. She may have had contract and tort theories offering different remedies for this harm. But that does not change the fact that both theories sought to remedy the same harm and thus to vindicate the same primary right.⁵