 None of these versions of the sanction theory survived H.L.A. Hart’s criticisms (Hart 1961 [1994: 27–42]; cf. Hacker 1973; but see Schauer 2015 for a recent reformulation of this approach). First, they misleadingly represent a range of disparate legal consequences—including compensation and even invalidation—as if they all function as penalties. Second, they render unintelligible many familiar references to duties in the absence of sanctions, for example, the duty of the highest courts to apply the law. Third, they offer an inadequate explanation of non-optionality. “You have an obligation not to murder” cannot merely mean “If you murder you will be punished”, for the law is not indifferent between people, on the one hand, murdering and being jailed, and on the other hand not murdering at all. “The right to disobey the law is not obtainable by the payment of a penalty or a licence fee” (Francome v. Mirror Group Newspapers Ltd. [1984] 2 All ER 408 at 412). Such dicta are commonplace and reflect familiar judicial attitudes. Most important, the normal function of sanctions in the law is to reinforce duties, not to constitute them. It is true that one reason people are interested in knowing their legal duties is to avoid sanctions, but this is not the only reason nor is it, contrary to what Oliver Wendell Holmes supposed, a theoretically primary one (Holmes 1897). Subjects also want to be guided by their duties—whether in order to fulfil them or deliberately to infringe them—and officials invoke them as reasons for, and not merely consequences of, their decisions.