The publication of an obscene libel was an offence under the common law of England. Prior to the abolition by section 1 of the Criminal Law Act 1967 of the distinction between felony and misdemeanour, it was regarded as a misdemeanour. It has been abolished in England and Wales and Northern Ireland. The existence of this offence was denied by Hawkins; and by Holt, C.J., who said that it was within the jurisdiction of the spiritual courts.