Lowe, later First Viscount Sherbrooke, brought forward the Bill that created the joint stock limited liability company. It was the first nationwide codification of company law in the world, and he has recently been described as "the father of modern company law". Our company law continues to have an excellent record. Since 1997 new incorporations have risen by over 60 per cent and the number of foreign firms incorporating in the UK has more than quadrupled. No doubt this is because, according to the World Bank's assessment, it is quicker and cheaper for companies to set up in the UK than in any other EU member state." In 1859, Lowe went to the Education Office as Vice-President of the Committee of the Council on Education in Lord Palmerston's ministry; there he pursued a vigorous policy, insisting on payment by results, and bringing in the revised code (1862), which embodied this principle and made an examination in "the three R's" the test for grants of public money. He felt then, and still more after the Reform Act of 1867, that "we must educate our masters," and he rather scandalized his old university friends by the stress he laid on physical science as opposed to classical studies. Considerable opposition was aroused by the new regime at the Education Office, and, in 1864, Lowe was driven to resign by an adverse vote in Parliament with reference to the way in which inspectors' reports were "edited." This was the result of the strong feelings that had been aroused against Lingen's administration of the Education Office. Reform Lord Palmerston had been a towering opponent to widening democratic participation and his death in October 1865 opened the way to the Russell–Gladstone reform ministry, which introduced the Reform Bill of 1866. Lowe carried on his former Prime Minister's views, as part of the Canning and Peel Liberal school. Moreover, he had been heavily shocked by his experiences of the comparatively developed union movement in his time in Australia in a less rigid class system. He had already made known his objections to the advance of "democracy", notably in his speech in 1865 on Sir Edward Baines's Borough Franchise Bill. He was not invited to join the new ministry. Lowe retired into what Bright called the "Cave of Adullam", and with other Liberals and Whig peers (known collectively as the 'Adullamites' ) opposed the bill in a series