No legislation was ever passed in England that legalised slavery, unlike the Portuguese "Ordenações Manuelinas" (1481–1514), the Dutch "East India Company Ordinances" (1622), and France's "Code Noir" (1685), and this caused confusion when English people brought home slaves they had legally purchased in the colonies. In "Butts v. Penny" (1677) 2 Lev 201, 3 Keb 785, an action was brought to recover the value of 10 slaves who had been held by the plaintiff in India. The court held that an action for trover would lie in English law, because the sale of non-Christians as slaves was common in India. However, no judgment was delivered in the case.