The rule in "Dearle v Hall" has been controversial almost since its inception. In 1893, Lord Macnaghten said "I am inclined to think that the rule in "Dearle v Hall" has on the whole produced at least as much injustice as it has prevented." But this has not stopped it from being extended from a rule regulating the priority of interests in trusts to the regulation of the priority of proprietary interests in debts and other similar intangibles, such as rights under contracts, which is considerably more important in terms of modern commerce.