 In 1706 Chief Justice Holt refused an action for trover in relation to a slave holding that no man could have property in another, but held that an alternative action, trespass "quare captivum suum cepit", would be available, which was actually felt to have strengthened the legal position of slaveowners.Ultimately the comments made in Holt's decisions had little long-term effect.In 1700 there was no extensive use of slave labour in England as there was in the colonies.