No need prove causal link between accomplice's
actions and commission of offence
R v Gnango
Principal offender innocent -
accomplice charged as Principal
R v Bourne
R v Cogan and Leek
Aid, abet, counsel or procure the
commission of an offence
Doing anything after the principal offence
has been committed is none of these
Procurement does not require knowledge
of the principal offence
R v Clarkson
Wilcox v Jeffrey
Inc failure to act when
there is a duty to do so
DuCros v Lambourne
Tuck v Robson
R v Russell & Russell
Presence at crime scene not sufficient: R v Clarkson
MR
Intention to assist, encourage
or procure the principal offence
Specific intent required even if strict
liability offence: Callow v Tillstone
Deliberately doing the act of encouragement
suffices, it doesn’t matter if D didn’t want the result
of the principal offence to occur: NCB v Gamble
Being contractually obliged to assist is not a valid defence
Knowledge need not be specific only knowledge that a certain
type of offence is to be carried out is sufficient: R v Bainbridge
Maxwell v DPP
R v Howe
Knowledge of the circs of the principle offence =
knowledge of the “essential matter which constitute
the offence”: Youden v Johnson
Going beyond the scope of the plan
If PO goes beyond scope of plan AND D contemplated was a
real possibility PO commit more serious crime AND they
participated, D liable for more serious offence: R v Hyde
Inc tacit agreements: R v Slack
R v Lovesey and Peterson
PO deliberately exceeds plan, accomplice not liable
for the unauthorised excessive part of the plan: R v
Dunbar; R v Anderson and Morris
For murder, accomplice must anticipate PO will kill or
GBH: R v Powell; A, B, C and D v R
Plan to GBH (not kill), accomplice not liable if PO
commits a murder in a way that is ‘fundamentally
different’ to that envisaged by the accomplice: R v English
R v Rahman
R v Yemoh
R v Gilmour
Withdrawal from a plan
Person can validly withdraw from plan: R v Grundy
R v Beverra
The communication must be an unequivocal, effective
and timely communication of intention to withdraw