The belief that educational leaders need to be ethical decision-makers is recent. Thomas and Bainbridge suggest that an educational leader needs to develop technical competency in ethical leadership. Yet few leaders in schools have been trained in conflict resolution of an ethical nature and little importance has been given to this within existing administrators' training programmes. If ethical leadership "... seeks to develop human potential" (Novak 2002: 14) and as ethical leaders "... inspire commitment... sustain hope and participation" (Moore, 1996: abstract), in what ways should educational leaders be trained to help them make fair ethical decisions? The exploration of past philosophical foundations compared with more recent perspectives will help individuals to respond to this question. It is posited that these two approaches point towards an advocacy for the need for a multicultural paradigm approach to decision-making and form the subject of this paper.