 This case was one of the first tests of "Habeas Corpus" when the gaoler had no colour of state; the writ had been conceived in the midst of the English Civil War as the Habeas Corpus Act 1640, in order to defend the subject from government tyranny.Similar uses are seen today in India, where the confinement is in a madrasa.Davy died on 13 December 1780, and was buried in Newington Butts.