In the case of Malone v Metropolitan Police Commissioner, [1979] CH 344 the court refused to support the plaintiff's argument that he had a right to privacy. In contrast to the cases discussed earlier (see section 4.3.1.1), where the courts were criticised for judicial law-making in areas of significant public importance, the court in Malone can be seen to have been more deferential and conscious of not encroaching on to what it saw as the legislature's territory.