 In a contrary view, Devlin himself argued that this was not a special defence for doctors, because the underlying disease, and not medical treatment, was the true cause of death, although a minority of critics have argued that, if a treatment hastens death, that treatment is the immediate cause of death, while accepting the principle of double effect on the basis on the basis that a doctor might have no guilty intention.More recently, the double effect principle figured in two British murder trials, both of were decided in line with Devlin's 1962 clarification of the principle.In 1990, Dr Cox, a rheumatologist was convicted of the murder of a terminally ill patient who had begged him to kill her.