The first attempted prosecution of a husband for the rape of his wife was "R v Clarke" (1949). Rather than try to argue directly against Hale's logic, the court held that consent in this instance had been revoked by an order of the court for non-cohabitation. It was the first of a number of cases in which the courts found reasons not to apply the exemption, notably "R v O’Brien" (1974) (the obtaining of decree nisi), "R v Steele" (1976) (an undertaking by the husband to the court not to molest the wife) and "R v Roberts" (1986) (the existence of a formal separation agreement).