Oblique intent, foresight and authorisation

In R v Jogee, the Supreme Court of the United Kingdom (UKSC) abolished a contentious doctrine of criminal law which allowed accomplices to a crime A to be convicted of another’s crime B on the basis that they foresaw commission of the latter in the course of the former. The Court held that nothing short of an intention to assist or encourage crime B would suffice to fix the accomplice with criminal liability. At common law intention has traditionally been understood to entail acts and consequences that were either achieved with purpose (direct intent) or foreseen as virtually certain to follow one’s chosen course of conduct (oblique intent). This paper argues that Jogee constitutes a first step away from a conception that measures ‘guilty minds’ in degrees of foresight: by associating the accessory’s intent to assist or encourage the perpetrator’s crime with ‘authorisation’, Jogee seems to support the view that intention in the legal sense depends ultimately on whether the accused had endorsed the consequences of his and the perpetrator’s actions

Joint enterprise, murder and substantial injustice: the first successful appeal post-Jogee (case comment)

This paper analyses the Court of Appeal decision in R v Crilly [2018] EWCA Crim 168. This was the first out-of-time appeal after R v Jogee in which the applicant succeeded in demonstrating ‘substantial injustice’ and having his murder conviction vacated. Although the judgment demonstrates that the Court remains faithful to its approach in R v Johnson and the high threshold test of ‘substantial injustice', Crilly suggests that if it can be shown that an applicant's case was in essence about foresight, the odd reference to intention might not prove fatal to demonstrating that had the jury been given Jogee-compliant directions on accessorial liability, this would have made a difference to their verdict

Magnetoresistor monitors relay performance

Magnetoresistor monitors the action of relays without disturbing circuit parameters or degrading relay performance. The magnetoresistor measures the relay magnetic flux produced under transient conditions to establish the characteristic signature of the relay