Five years later, in Scotland, the High Court of Justiciary took a different view, abolishing marital immunity, in "S. v. H.M. Advocate", 1989. The same happened in England and Wales in 1991, in "R v R" (see below). Very soon after this, in Australia, at the end of 1991, in "R v L", the High Court of Australia ruled the same, ruling that if the common law exemption had ever been part of the Australian law, it no longer was (by that time most Australian states and territories had already abolished their exemptions by statutory law).