In 1823, Parliament eased restrictions on licensed distilleries with the "Excise Act", while at the same time making it harder for the illegal stills to operate. Magistrates found counsel for the Crown appearing in their courts, so forcing the maximum penalties to be applied, with some cases removed to the Court of Exchequer in Edinburgh for tougher sentences. Highland landowners were now happy to remove tenants who were distillers in clearances on their estates. These changes ushered in the modern era of Scotch production: in 1823 2,232,000 gallons of whisky had duty paid on it; in 1824 this increased to 4,350,000 gallons.