In the 12th century, any death by misadventure without a "presentment of Englishry" was sufficient for a jury finding of murder, even in cases where there was no suspect and the victim's identity is unknown. The murder fine was levied in these cases under the Laws of Henry until 1267, when the fine for death by misadventure was abolished by the Statute of Marlborough during the baronial reform movement. The primary meaning of "" continued to be murder fine until the fine was abolished by the Engleschrie Act of 1340.