In German criminal law, causing bodily harm is justified by the victim’s consent unless the act, regardless of the consent given, violates public morals (§ 228).The Federal Court of Appeals has basically interpreted this restriction to apply to instances of life-threatening harm, but not to violations of majority moral views. However, the Court has made new judgements in two recent cases concerning mass brawls to widen the range of punishment of bodily harm with the victim’s consent. This study introduces and examines these two cases in particular.