Duress CasesLYNCH v ppp for Northern Ireland 1975 Duress not available for attempted murder D was an accessory to murder in that he drove a car to a place under threats from an IRA gunman M. D waited while M and his associates killed a policeman, and then drove them away. Held: A 3-2 majority in the House of Lords allowed his defence of duress. [The decision to allow the defence of duress to an accessory to murder has since been overruled in HOWE Lord Simon (dissenting) + The threat must be a threat of death or serious personal injury; + Threats to damage property, or threats of any other kind, are not sufficient. Not guilty but would be nowR v HOWE 1987 Duress not available in murder or attempt D acting under duress, took part with others in two separate murders, and on a third occasion the intended victim escaped. Held: Using the 1966 Practice Statement to depart from the decision in Lynch. — overruled Duress is not available as a defence to murder either to a principal or accessory. Morals, law and policy should deny a man the right to take an innocent life even at the price of his own. Lord Hailsham; ”.. the overriding objects of the criminal law must be to protect innocent lives and to set a standard of conduct which ordinary men and women are expected to observe if they are to avoid criminal responsibility...” Guilty