Following this decision, the doctrine of ex turpi causa had a very limited application, and some commentators noted that the decision "for all practical purposes, makes the defence of illegality inapplicable to negligence actions."[3]
The Supreme Court revisited the doctrine in British Columbia v. Zastowny,[4] where they applied the decision in Hall to hold that a person is not entitled to compensation for unemployment during a prison sentence, except in circumstances such as a wrongful conviction. This followed from the rationale that such compensation would create a clash between the criminal justice system and civil law, which would compromise the integrity of the legal system.