Chapter 9 Interactive key cases

The House of Lords dismissed his appeal against conviction for conspiracy. It was not necessary to establish an intention on the part of each conspirator that the offence or offences in question should in fact be committed; it was sufficient to show that he had known that the course of conduct to be pursued would amount to the commission of an offence and that he had intended to play some part in the agreed course of conduct in furtherance of the criminal purpose that it had been intended to achieve.

Lord Bridge, dismissing D’s appeal against conviction, held that in respect of s 1 Criminal Attempts Act 1981 the jury should consider two questions (and notwithstanding that the commission of the actual offence was, on the facts, impossible):

Did the defendant intend to commit the offence which it is alleged he attempted to commit?
Did he, in relation to that offence, do an act which was more than merely preparatory to the commission of the intended offence?

For an attempted offence, it must be shown that D intended to produce the actus reus. In this case it had to be shown that the defendants intended the property to be ‘criminal property’.

Anderson [1986] AC 27

Shivpuri [1987] AC 1

Pace and Rogers [2014] EWCA Crim 186