 In recent literature, the ‘bundle of rights’ conception has encountered resistance. Some theorists want to insist that property is better conceived, as it is in colloquial usage, as a substantial relation between a person and a thing (Penner 2000 and Smith 2012). This can be put forward on analytic grounds or for ideological reasons; on the latter approach it is said that the importance of property for a free society is obscured when the ownership relation is treated as a divisible bundle of rights (Attas 2006).