 Proponents of the principle of double effect have always acknowledged that a proportionality condition must be satisfied when double effect is applied, but this condition typically requires only that the good effect outweigh the foreseen bad effect or that there be sufficient reason for causing the bad effect. Some critics of the principle of double effect have maintained that when double effect has been invoked, substantive independent justifications for causing the kind of harm in question are implicitly relied upon, and are in fact, doing all of the justificatory work. These independent considerations are not derived from the distinction between intended and merely foreseen consequences and do not depend on it (Davis (1984), McIntyre (2001)). If this criticism is correct, then perhaps the cases that have traditionally been cited as applications of the principle of double effect are united only by the fact that each is an exception to the general prohibition on causing the death of a human being.