Thanks Jason.
The problem with this is the results page is created by the user through a search using 'get': For example the URL may be :
http://www.domain.com/results.php?id=1 or http://www.domain.com/results.php?id=2
In other words the results page they need to be sent back to is dynamic and different in every case.
From my understanding using the code you mention I can only send them back to a generic results page. ie results.php without the search criteria created through a form (?id=1). Hence the reason for using a Javascript back history approach on the Continue Shopping button. The problem with this is that it will not work if a user empties or removes from the cart as they will have to click multiple times on the Continue Shopping button.