In the early development of the law relating to transitory actions, the rule was loosened so that the plaintiff may specify the venue in any county he/she desired. However, this led to abuses and in the 15th century, the statutes of Richard II and Henry IV reimposed strict requirements of laying the correct venue. However, the effects of these statutes was diminished by the use of a legal fiction (e.g. allegation that the "foreign place" was situated in the London parish of St. Marylebone).