Gender biased- androcentric, all male sample, what he used to form his levels, issues as it is is beta biased and not generalisble to women and lacks external validity, however he generalised this to women Suggested women reason on a lower level than men but instead more recent research by his assistant gilligan has found they are nto at a lower level of reasoning however just reason in an alternate way whilst men reason on a basis of law and justice whilst women reason on a basis of compassion and caregiving, she criticised kholberg for overlooking this relational perspective in morality.