DPP for Northern Ireland v Maxwell

An accessory is guilty of any crime within the range of offences that he contemplated as being one that the principal might commit.

Citation
[1978] 1 WLR 1350
Court
House of Lords
Year
1978
Subject
Criminal Law
Topic
Inchoate offences and accessorial liability

Facts

Mr Maxwell was a member of the Ulster Volunteer Force, a paramilitary organisation. He was told to drive his car to guide another car, carrying members of the organisation, to an inn. He knew that they intended to carry out an attack of some kind, but not exactly what. When they arrived, one of the men in the other car threw a pipe bomb into the inn, but it was discovered and defused. Mr Maxwell was convicted of doing an act with intent to cause an explosion, and of possession of a bomb.

Legal principle

The House of Lords upheld the convictions. Lord Scarman said that a person who aids another in committing a crime is guilty of any offence that falls within the range of offences that he contemplated as being one of those that the principal might commit. Mr Maxwell knew that he was guiding the men to an attack, and the use of a bomb was one of the offences within the range of crimes that he must have contemplated. This extended the principle in R v Bainbridge.

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