... see what happens and taking appropriate steps to produce the offence, this is procuring the offence. Voluntary presence at the scene of a crime is insufficient, some active help is needed (Coney7). A counselled offence must have been committed by the person counselled, therefore there must be (I) contract between the parties, (ii) connection between the counselling and the offence, (iii) and the crime must be in the scope of authority or advice given, Calhaem8: some arrangement is necessary, encouragement can be offering money. Ostensibly, the basis for the accomplice's liability is his mens rea, that is, his intention to do the acts of assistance and encouragement that must be proved. Moloney9 provides that intention should have its common meaning i.e. the accomplice's act must be voluntary, although Clarkson10 says this can be inferred from knowledge of all the circumstances. It is not however merely desire or motive which ...

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