relation to the deaths of the other 95 victims, but a charge could not apply in relation to Bland because he died outside of the time limit that was applicable for the time of the alleged offence. Moral and legal issues The case brought up a number of moral and legal issues. As a result, the number of previous cases referred to is extensive. This case is another which delegated to the Bolam standard. This was a test introduced by the courts in Bolam v. Friern Hospital Management Committee. The essence of the Bolam standard is such as to remove liability from medical staff if the treatment they have provided to a patient under the particular circumstances would have been followed by a responsible body of medical personnel, exercising due skill and care in the process. Under Bolam, a doctor need only show that he was following an accepted medical practice – even if that practice was only followed by a minority of medical professionals. This was one of the arguments put forward on behalf of Dr Howe; that it would be intolerable if Dr Howe was charged with murder for following what he submitted to be generally regarded as good medical practice. A long-time critic of the Bland case, Dr Jacqueline Laing argues that the implications of the judicial decision deserve revisiting given recent Freedom of Information Act requests revealing financial incentives and staggering compliance in rolling out the 2008 NHS End-Of-Life Care strategy. She warns that Bland has been dangerously extended by the Mental Capacity Act 2005 so that novel third parties now have power to remove treatment. Andrew Devine Tony Bland was one of two people injured at Hillsborough to have been diagnosed as being in a persistent vegetative state. The other was 22-year-old Andrew Devine, from the Liverpool area, who also suffered massive brain damage as a result of being deprived of oxygen due to crush injuries. In the immediate aftermath of the disaster, his parents were warned by doctors that he was likely to die within a few months. In 1994, five years after the disaster and one year after the death of Tony Bland, Devine's family claimed to have seen him following a moving object with his eyes. By March 1997, Devine was able to communicate to others using a touch-sensitive buzzer to answer "yes" or "no" to questions asked. By the time of