Social reformer Jeremy Bentham wrote the first known argument for homosexual law reform in England around 1785, at a time when the legal penalty for buggery was death by hanging. His advocacy stemmed from his utilitarian philosophy, in which the morality of an action is determined by the net consequence of that action on human well-being. He argued that homosexuality was a victimless crime, and therefore not deserving of social approbation or criminal charges. He regarded popular negative attitudes against homosexuality as an irrational prejudice, fanned and perpetuated by religious teachings. However, he did not publicize his views as he feared reprisal; his powerful essay was not published until 1978.