... of 1997 was passed the law on conspiracy became a mix of statute law and common law. There are two areas of conspiracy which are common law offences, these are conspiracy to defraud and conspiracy to corrupt public morals or outrage public decency. The Criminal Law Act 1977, specifically retained conspiracy to defraud as a common law offence, while abolishing most other forms of common law conspiracy, in anticipation of early reform. This never materialised, and reforms of this area of the law have been promised for decades. Conspiracy to defraud 'acts as a safety net to ensure that certain offenders do no escape punishment' (Diana Roe, Criminal Law second edition) these punishments, as seen in section 12 of the Criminal Law Act 1977, can be up to a maximum of ten years' imprisonment. Although common law conspiracy has been criticised, it is however useful in a number of situations, including: ...

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