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The Extension of Complicity

THREE recent decisions settle the law of complicity in an extended sense. On many occasions the courts have said that an accessory must know the facts, but there have been some contrary decisions. Now, in a case reported only in a rather obscure series, a Divisional Court has extended liability to persons charged as accessories who were reckless as to the offence being committed: Carter v. Richardson [1974] R.T.R. 314. On this basis the supervising driver of a learnerdriver whose blood-alcohol concentration was above the limit was held to have aided and abetted the offence because the supervisor " was aware that the principal consumed an excessive amount of alcohol or was reckless as to whether he had done so." The supervisor had not actively contributed to the offence, but in continuing to sit with the driver and thus legalising the act of driving he had implicated himself in it. It is of some interest to note that in at least one and possibly two respects the decision clashes with proposals of the Law Commission Working Party on Codification. The Working Party would exclude recklessness as sufficient mens rea for an accessory, and were against the view that a person could be held to be an accessory merely because he failed to prevent the offence (Law Commission Working Paper No. 43). In the present case the supervisor had brought himself to the unfavourable attention of the police by claiming at first to have been the actual driver, in order to protect the learner-driver, and confessed the truth only after it was established that he himself was above the blood-alcohol limit. Would he have been charged if it had not been for this? The second case, Attorney-General's Reference (No. 1 of 1975) [1975] 3 W.L.R. 11, also concerned the blood-alcohol legislation. A driver was convicted of having an excess concentration of alcohol, and in order to persuade the court that there were " special reasons " for not disqualifying him he offered evidence that his drink had been surreptitiously " laced" with spirits by a friend. Probably (although the report does not say so) the story was corroborated by his friend; at any rate the friend was then indicted for aiding and abetting the offence, on the basis that he knew that the driver would shortly be driving the car home. (One does not need to be told that the object of the prosecution was to reduce the popularity of the