In Nothman v. London Borough of Barnet, Lord Denning of the Court of Appeals attacked "those who adopt the strict literal and grammatical construction of the words" and saying that the "[t]he literal method is now completely out-of-date [and] replaced by the . . . 'purposive' approach".[44] On appeal, however, against Denning's decision, Lord Russell in the House of Lords "disclaim[ed] the sweeping comments of Lord Denning".[45]