In Ireland, the Criminal Law (Rape) Act, 1981 defined rape as "unlawful sexual intercourse" without consent; an attempt to explicitly include spouses within the definition was rejected by the Fianna Fáil government. Seán Doherty, the Minister for Justice, suggested that the courts might allow a charge of rape in some cases, and that various assault charges might be prosecuted in others. A 1987 discussion paper by the Law Reform Commission stated, "In the absence of Irish decisions on the topic, the present law cannot be stated with any great degree of confidence. It would appear, however, that to the extent that the marital rape exemption exists, it is confined to circumstances where the spouses are cohabiting and there are no separation proceedings in being, or even, perhaps, in contemplation." The paper's call to abolish any marital exemption was "on the whole, generally welcomed, although some misgivings were expressed as to whether it might not lead to fabricated complaints and unwarranted intrusions in the marital relationship." The Criminal Law (Rape) (Amendment) Act, 1990 removed the word "unlawful" from the 1981 definition of rape, and abolished "any rule of law by virtue of which a husband cannot be guilty of the rape of his wife". The first two convictions were in 2006 (upon retrial) and 2016.