 The path to reconciling the harm principle with utilitarianism is often thought to be some form of indirect utilitarianism (Gray 1996; Mulgan 2007: 117–119). The distinction is drawn between a criterion of rightness and a decision procedure (Mulgan 2007: 117–119). Thus, on this indirect view the words “actions are right in proportion as they tend to promote happiness, wrong as they tend to produce the reverse of happiness” is not any part of a decision procedure; it is a criterion of rightness. Sometimes, perhaps often, a criterion of rightness will itself feature heavily in a decision procedure. But at other times a decision procedure will not contain the supreme criterion of rightness. Acting always to promote happiness or minimize unhappiness may be self-defeating for various reasons or impossible in the practical circumstances of ignorance that ordinary people face. Over the course of a lifetime and across all the activities of a legal system, more utility will be produced and disutility avoided if the harm principle has the place Mill argues it has, despite the fact that this will repeatedly require the sacrifice of some utility in day to day legal dealings. Much of this, for Mill, relates to the importance of human liberty to happiness (Gray 1996: 136). Demonstrating that one can really derive something as strong as the harm principle (“to govern absolutely”) in this way is a formidable challenge. It is subject, among other things, to scepticism about the workability of the distinction between criterion of rightness and decision procedure (Griffin 1994; Mulgan 2007). John Gray’s book-long attempt to spell out how the harm principle can be underpinned by indirect utilitarianism came to be repudiated by Gray himself (Gray 1996: postscript) . Contemporary consequentialism, however, continues to flourish (Sinnott-Armstrong 2019); and many accounts of the harm principle still see a form of utilitarianism as the best grounding for the harm principle (Sumner 2004, 2011). Moreover, there are non-utilitarian writers making related arguments in support of the harm principle. Les Green for example argues that