their estate forfeited to the Crown, while survivors of suicide attempts could be punished by imprisonment or death. Posthumous punishment stopped in the 19th century, and appetite for punishing survivors of suicide attempts waned until this was decriminalised by the passing of the Suicide Act 1961 and the Criminal Justice Act (Northern Ireland) 1966; these same acts made it an offence to assist in a suicide. With respect to civil law the simple act of suicide is lawful but the consequences of dying by suicide might turn an individual event into an unlawful act, as in the case of Reeves v Commissioners of Police of the Metropolis [2000] 1 AC 360, where a man in police custody hanged himself and was held equally liable with the police (a cell door defect enabled the hanging) for the loss suffered by his widow; the practical effect was to reduce the police damages liability by 50%. In 2009, the House of Lords ruled that the law concerning the treatment of people who accompanied those who died of assisted suicide was unclear, following Debbie Purdy's case that this lack of clarity was a breach of her human rights. (In her case, as someone with multiple sclerosis, she wanted to know whether her husband would be prosecuted for accompanying her abroad where she might eventually wish to die of assisted suicide, if her illness progressed.) Scotland Suicide was never a statutory criminal offence. Under Scots Law, survivors of suicide attempts may be arrested and prosecuted for associated common law offences such as breach of the peace or culpable and reckless conduct. Although the Scottish Government has never legislated to formally decriminalise suicide, a 2009 Appeal Court case, which found that a breach of the peace must have an element of disruption to the community, substantially reduced the likelihood of securing a successful prosecution for suicide attempts. Subsequently the Crown Office and Procurator Fiscal Service instructed Police Scotland to deal with cases of attempted suicide which come to their notice by means other than arrest, even where an offence such as breach of the peace may have been committed. Police Scotland has advised officers: Despite these recommendations, occasional arrests and prosecutions for suicide attempts continue. Consequential liability upon a person attempting suicide (or if dead, his/her estate) might arise under civil law where it parallels the civil liabilities recognised in the (English Law) Reeves case mentioned