 The Act was held to apply in the case of "Sutton v. Mitchell", (1785) 1 T.R.18, where goods were stolen from a ship moored in the Thames by robbers colluding with a member of the crew.However, this emphasised the liability shipowners were still exposed to in cases where the goods were stolen without the involvement of the crew; as a result, a second petition was brought to the House, leading to the passage of the Merchant Shipping Act 1786.