Lord Hailsham's speech in "Broome v Cassell" is cited today in relation to the hierarchical nature of the English legal system and for lower courts' duty in following the decision of higher courts. The parts of "Rookes v Barnard" concerning exemplary damages remains good law, although they have been rejected in most leading Commonwealth jurisdictions. Irving continued to provoke controversy, later becoming a prominent Holocaust denier. He was later involved in "Irving v Penguin Books Ltd", another high-profile libel suit.