<p>In the past, I have argued that both relational and non-relational moral obligations are fundamentally second personal notions that imply different forms of accountability (Darwall 2006, 2013). Relational obligations, which are owed by an obligor to an obligee, involve <i>personal</i> accountability of the obligor to the obligee and that the obligee has an <i>individual</i> authority over the obligee. The latter gives the obligee the standing to insist on performance and to seek compensation if the obligation is violated. Non-relational obligations are not owed to anyone in particular. They imply accountability but not to anyone <i>in particular</i>, rather to the moral community or to any person as its representative; anyone has the <i>representative</i> authority to hold the obligor accountable on the moral community’s behalf. R. Jay Wallace has argued that morality is relational through and through and that there is no such thing as non-relational obligation. I argue here that although private law can be grounded in relational moral obligations, the criminal law cannot be. Criminal law can be justified only if there is such a thing as non-relational morality.</p>