There was at one time an issue of impossibility in that defendants may be dishonest and intend to handle goods (which they believe to be stolen) but which are not in fact stolen. The House of Lords ruled in Haughton v. Smith (1973) that where goods previously stolen have been reduced into lawful possession, not only can they not be handled, but there can be no attempt to handle them. Since then, section 1 of the Criminal Attempts Act 1981 confirms that such a defendant can be convicted.