Lastly, an analysis of case law reveals that the six section 15 claims to reach the Supreme Court immediately following the "Law" decision were all denied on the ground they did not fulfill the human dignity requirement. However, another analysis of section 15 claims reports that the success rate of claimants under "Law" was greater than the success rate under "Andrews". One scholar has explained this phenomenon by suggesting "Law" did not create a new test of human dignity, but rather that the court crystallized a pre-existing yet implicit criterion into law. That said, a disproportionately high number of section 15 claims under "Law" fail at this third stage of the test (63.6%).