In the colonial era, the death penalty for apostasy was abolished in Islamic countries that had come under Western rule or in places, such as the Ottoman Empire, Western powers could apply enough pressure to abolish it. Writing in the mid 1970s, Rudolph Peters and Gert J. J. De Vries stated that "apostasy no longer falls under criminal law" in the Muslim world, but that some Muslims (such as 'Adb al-Qadir 'Awdah) were preaching that "the killing of an apostate" had "become a duty of individual Moslems" (rather than a less important collective duty in "hisbah" doctrine) and giving advice on how to plead in court after being arrested for such a murder to avoid punishment.