R v Bainbridge
An accessory need not know the precise details of the crime to be committed, as long as he knows the type of crime intended.
Facts
Mr Bainbridge bought oxygen cutting equipment, which was used about six weeks later to break into a branch of the Midland Bank in Stoke Newington. He said that he had bought the equipment for someone else, and that, although he suspected it was going to be used for something illegal, such as breaking up stolen goods, he did not know that it would be used for breaking into a bank. He was convicted of being an accessory before the fact to the burglary.
Legal principle
The Court of Criminal Appeal upheld the conviction. Lord Parker CJ said that it is not enough that the accessory knows that some illegal venture is intended. But it is not necessary to prove that he knew the particular crime that was intended, in the sense of knowing the date and place. It is enough that he knew that a crime of the type in question was intended, such as breaking and entering premises and stealing property from them.
Related cases on inchoate offences and accessorial liability
- Attorney General's Reference (No 1 of 1975) [1975] QB 773
- Attorney General's Reference (No 1 of 1992) [1993] 1 WLR 274
- DPP for Northern Ireland v Maxwell [1978] 1 WLR 1350
- Haughton v Smith [1975] AC 476
- National Coal Board v Gamble [1959] 1 QB 11
- R v Anderson [1986] AC 27
- R v Becerra and Cooper (1975) 62 Cr App R 212
- R v Campbell (1991) 93 Cr App R 350
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