however, the sovereign would reappoint all members of the council after its dissolution. In practice, therefore, membership continued without a break. In 1901, the law was changed to ensure that Crown appointments became wholly unaffected by any succession of monarch. The sovereign, however, may remove an individual from the Privy Council. Former MP Elliot Morley was expelled on 8 June 2011, following his conviction on charges of false accounting in connection with the British parliamentary expenses scandal. Before this, the last individual to be expelled from the Council was Sir Edgar Speyer, Bt., who was removed on 13 December 1921 for collaborating with the enemy German Empire, during the First World War. Individuals can choose to resign, sometimes to avoid expulsion. Three members voluntarily left the Privy Council in the 20th century: John Profumo, who resigned on 26 June 1963; John Stonehouse, who resigned on 17 August 1976 and Jonathan Aitken, who resigned on 25 June 1997 following allegations of perjury. So far, four Privy Counsellors have resigned in the 21st century, three in the same year. On 4 February 2013, Chris Huhne announced that he would voluntarily leave the Privy Council after pleading guilty to perverting the course of justice. Lord Prescott stood down on 6 July 2013, in protest against delays in the introduction of press regulation, expecting others to follow. Denis MacShane resigned on 9 October 2013, before an Old Bailey hearing at which he pleaded guilty of false accounting and was subsequently imprisoned. In April 2022, former Prime Minister of Jamaica P. J. Patterson resigned to make the case for Jamaica to become a republic. Rights and privileges The Privy Council as a whole is termed "The Most Honourable" whilst its members individually, the Privy Counsellors, are entitled to be styled "The Right Honourable". Nonetheless, some nobles automatically have higher styles: non-royal dukes are styled "The Most Noble", and marquesses as "The Most Honourable". Modern custom as recommended by Debrett's is to use the post-nominal letters "PC" in a social style of address for peers who are Privy Counsellors. For commoners, "The Right Honourable" is sufficient identification of their status as a Privy Counsellor and they do not use the post-nominal letters "PC". The Ministry of Justice revises current practice of this convention from time to time. Each Privy Counsellor has the right of personal access to the sovereign. Peers were considered to enjoy this right