Page was not the first British soldier to “murder” a foreigner on foreign soil, nor was he the first to be tried and convicted by a court-martial for so doing. He was, however, the first to take advantage of the passing of the Courts-Martial (Appeals) Act, 1951, upon such a conviction. His case thus provided at last an authoritative ruling on a point which had previously been the silent responsibility of the Judge Advocate General, namely, whether such a killing could indeed be murder within the meaning of section 41 of the Army Act, 1881.