conjugal rights to sexual intercourse with each other. This can be seen in English common law, in force in Anglo America and the British Commonwealth, where the very concept of marital rape was treated as an impossibility. This was illustrated most vividly by Sir Matthew Hale, (1609-1676), in his legal treatise Historia Placitorum Coronæ or History of the Pleas of the Crown (posthumously, 1736) where he wrote that "The husband cannot be guilty of a rape committed by himself upon his lawful wife, for by their mutual consent and contract the wife hath given up herself in this kind unto her husband, which she cannot retract." Formalization of the marital rape exemption in law Common law and the United Kingdom Sir Matthew Hale's statement in History of the Pleas of the Crown did not cite a legal precedent for it, though it relied on earlier standards. In a case of Lord Audley's (1488–1544), for instance, Hale cite's the jurist Bracton (c. 1210c. 1268) support of this rule, said to have derived from laws of King Æthelstan (r. 927–939) where upon the law holds that even "were the party of no chaste life, but a whore, yet there may be ravishment: but it is a good plea to say she was his concubine". A lawful marriage legitimizes the conjugal act itself, so "marital rape" is a contradiction in terms. While a physical assault against a spouse may be charged, such is distinct from the delegitimization of conjugal union itself as rape. Marriage then should not be defined as an "exemption" to rape but as "contradictory" to it. Marriage created conjugal rights between spouses, and marriage could not be annulled except by a private Act of Parliament—it therefore follows that a spouse could not revoke conjugal rights from the marriage, and therefore there could be no rape between spouses. The principle was repeated in East's Treatise of the Pleas of the Crown in 1803 and in Archbold's Pleading and Evidence in Criminal Cases in 1822. The principle was framed as an exemption to the law of rape in an English courtroom in R v Clarence, but it was not overturned until 1991 by the House of Lords in the case of R. v. R in 1991, where it was described as an anachronistic and offensive legal fiction. Feminist critique in the 19th century From the beginnings of the 19th century feminist movement,