In the decades since Salomon's case, various exceptional circumstances have been delineated, both by legislatures and the judiciary, in England and elsewhere (including Ireland) when courts can legitimately disregard a company's separate legal personality, such as where crime or fraud has been committed. There is therefore much debate as to whether the same decision would be reached if the same facts were considered in the modern legal environment, given the House of Lords' decisions in "Pepper v Hart" and "Re Spectrum Plus Ltd" and the Privy Council in "Attorney General of Belize v Belize Telecom Ltd" that require a purposive approach to interpreting legislation. In 2013 there was a systemic review of these authorities in "Prest v Petrodel Resources Ltd" and Lord Sumption distinguished between cases of truly "piercing the corporate veil" and situations where it was held that the company was essentially an agent for a wrongdoer or held property on trust.