The courts did not recognise contracts which were equivalent to slavery or servitude. The courts have been reluctant to force individuals to work and have declined to enforce contracts of service. Forced labour is however permitted in certain limited circumstances: the Crown can theoretically compel persons to undertake naval service and prisoners can be forced to work whilst serving their sentences. The Supreme Court of the United Kingdom considered the forced labour prohibition in Caitlin Reilly and Jamieson Wilson v Secretary of State for Work and Pensions, where it ruled that the Department for Work and Pensions' workfare policy under which the unemployed work in return for their benefit payments were not forced labour but were nevertheless legally flawed. The right to liberty of the person, to be free from the domination or servitude of others, and only to lose one's liberty 'by lawful judgment of his Peers, or by the Law of the Land' has been fundamental to UK and English law since the Magna Carta. This said, slavery and serfdom took until the 16th century to break down in England, and was maintained at least until 1833 within the British Empire, before full abolition of forced labour was passed, extending the writ of habeas corpus (the right to one's own body) to everyone. Benjamin Franklin's adage, that people who sacrifice liberty for security will lose both and deserve neither, is reflected in human rights law. Like international law, the European Convention on Human Rights article 5 states no 'one shall be deprived of [their] liberty' unless law expressly allows that person's detention after conviction, a lawful arrest or detention on suspicion of an offence, detention of a minor for education, detention for health or stopping infectious diseases spreading, or for lawful deportation or extradition. People must be told reasons for any detention, be put on trial in a reasonable time, or released immediately with compensation if detention was unlawful. In practice, every power of the police or the state to maintain order and security 'inevitably means a corresponding reduction in the liberty of the individual', and the UK has among the highest spending on policing in the world. For this reason the Police and Criminal Evidence Act 1984, and the limits to police powers, is a key legislative guardian of liberty in the UK today. Three main issues of police power and liberty are (1) powers of arrest, detention and questioning, (2) powers to enter, search or seize property, and (3) the accountability of the police for abuse of power. First, the Police and Criminal Evidence Act 1984 section 1 allows a constable to stop and search people if a constable 'has reasonable grounds for suspecting' that they will 'find stolen or prohibited articles', they may seize the articles, and they may use reasonable force.