The reasoning outlined in the Howe case was followed in R v ESB Hotels Ltd which was also a case prior to the FSO, but which did involve offences contrary to the Fire Precautions Act 1971. In that case the Court of Appeal laid down the principles outlined in Howe and also indicated that it was often helpful to look at how far short of the appropriate standard of fire safety the Defendant fell in failing to meet the required standards of fire safety. The original combined fine of £400,000 was reduced to £250,000 because the Judge should have looked at the net turnover of the business and the effect of the fine on the Defendant’s business.