View source for Conspiracy (Offence)

{{LevelZero}}{{HeaderLiability}}
{{HeaderOffences}}

{{OffenceBox
|OffenceTitle=Conspiracy 
|OffencePage=Conspiracy 
|Section=465|Act={{OBCCC}} 
|CrownElection= {{OBIndictableElection}} (465(1)(b) and (c))<br> {{OBSummaryElection}} (465(1)(d)) |Jurisdiction=s. 465(1)(b), (c):<br>{{OBJurisdictionAll}}<br>s. 465(1)(a):<br>{{OBJurisdictionExclusive}}<br>s.465(1)(d):<br>{{OBJurisdictionSumm}} 
|Bail={{OBBailVar}} 
|SummaryDisp= {{OBDispAll}}
|SummaryMin= {{OBMinNone}}
|SummaryMax= {{OBSConviction}} 
|IndictableDisp= {{OBDisp14orLifeVar}}
|IndictableMin= {{OBMinNone}}
|IndictableMax= {{OBTime|5, 10 years}} or {{OBMaxLife}} }}

==Overview==
{{OverviewXIII|conspiracy}}

; Pleadings
<!--
{{PleadingsHeader}}
{{PleadingsIndictableList-N|s.  }}
{{PleadingsSummaryList|s. }}
{{PleadingsEnd}}
-->
{{PleadingsExclusive|s. 465(1)(a) {{DescrSec|465(1)(a)}} }}

{{PleadingsIndictElection|s. 465(1)(b) and (c)}}

{{PleadingsSummary|s. 465(1)(d)}}

; Release
{{ReleaseOnlyBail|s. 465(1)(a), (b)}}

{{ReleaseAllOptions|s. 465(1)(d)}}

:''Reverse Onus Bail''
{{ReverseOnusCirc}}

; Publication Ban
{{GeneralPubBan}}

; Offence Designations
{{DesignationHeader}}
|-
|s. 465 || {{OKMark}} <!--wire--> || {{OKMark}} <!--DO-->||{{OKMark}} <!--SPIO--> || {{XMark}} <!--consent-->
{{DesignationEnd}}
<!-- I'm NOT entirely sure on those designations -->
{{SeeBelowForAncillary}}

==Offence Wording==

{{quotation|
; Conspiracy
465 (1) Except where otherwise expressly provided by law, the following provisions apply in respect of conspiracy:
:(a) every one who conspires with any one to commit murder or to cause another person to be murdered, whether in Canada or not, is guilty of an indictable offence and liable to a maximum term of imprisonment for life;
:(b) every one who conspires with any one to prosecute a person for an alleged offence, knowing that they did not commit that offence, is guilty of
::(i) an indictable offence and liable to imprisonment for a term of not more than 10 years or an offence punishable on summary conviction, if the alleged offence is one for which, on conviction, that person would be liable to be sentenced to imprisonment for life or for a term of not more than 14 years, or
::(ii) an indictable offence and liable to imprisonment for a term of not more than five years or an offence punishable on summary conviction, if the alleged offence is one for which, on conviction, that person would be liable to imprisonment for less than 14 years;
:(c) every one who conspires with any one to commit an indictable offence not provided for in paragraph (a) or (b) is guilty of an indictable offence and liable to the same punishment as that to which an accused who is guilty of that offence would, on conviction, be liable; and
:(d) every one who conspires with any one to commit an offence punishable on summary conviction is guilty of an offence punishable on summary conviction.
(2) [Repealed, {{LegHistory80s|1985, c. 27 (1st Supp.)}}, s. 61]
<br>
...<br>
R.S., {{LegHistory80s|1985, c. C-46}}, s. 465; 
R.S., {{LegHistory80s|1985, c. 27 (1st Supp.)}}, s. 61;
{{LegHistory90s|1998, c. 35}}, s. 121;
{{LegHistory10s|2018, c. 11}}, s. 28;
{{LegHistory10s|2019, c. 25}}, s. 183.
|[{{CCCSec|465}} CCC]
}}

{{quotation|
; Conspiracy in restraint of trade
466 (1) A conspiracy in restraint of trade is an agreement between two or more persons to do or to procure to be done any unlawful act in restraint of trade.
<br>
; Trade union, exception
(2) The purposes of a trade union are not, by reason only that they are in restraint of trade, unlawful within the meaning of subsection (1).
<br>
R.S., {{LegHistory80s|1985, c. C-46}}, s. 466; {{LegHistory90s|1992, c. 1}}, s. 60(F).
|[{{CCCSec|466}} CCC]
}}

==Proof of the Offence==
{{ElementHeader}}
{{ElementLeft}}
{{Proving|conspiracy|465}}<ref>
''R v Root'', [http://canlii.ca/t/2200k 2008 ONCA 869] (CanLII){{perONCA|Watt JA}}{{atL|2200k|66}}
</ref>
{{InitialElements}}
# {{box}} the words communicated in the conspiracy
# {{box}} there was an agreement made between the parties
# {{box}} the parties had an intention to agree to put a "common design into effect" and did in fact agree
# {{box}} the parties did not change their minds or intention to put common design into effect
{{ElementEnd}}
{{reflist|2}}

==Interpretation==
The purpose of criminalizing conspiracies is to "prevent an unlawful object" from being fulfilled and then "prevent[ing] serious harm from occurring". Parliament intended to intervene "earlier along the continuum of the increased danger represented by a cohort or wrongdoers acting in concert".<ref>
''R v Dery'', [2006] 2 SCR 669, [http://canlii.ca/t/1q1hs 2006 SCC 53] (CanLII){{perSCC|Fish J}}{{atL|1q1hs|44}}<br> 
''R v Meyer'', [http://canlii.ca/t/fvj4v 2012 ONCJ 791] (CanLII), [2012] OJ No 6235{{perONCJ|Pacciocco J}}{{atL|fvj4v|21}}("The law of conspiracy achieves this policy [of preventing serious harm from occurring] by allowing a pre-emptive strike where there is a true agreement to achieve a mutual criminal objective.")
</ref>

A conspiracy is an agreement between two or more persons to do an unlawful act.<ref>
''R v O'Brien'', [http://canlii.ca/t/21v9k 1954 CanLII 42], [1954] SCR 666{{perSCC|Taschereau J}}{{atps|668-9}}<br>
See: ''R v Paradis'', [http://canlii.ca/t/fsmsh 1933 CanLII 75] (SCC), [1934] SCR 165, 61 CCC 184 (SCC){{perSCC|Rinfret J}}{{atp|186}} - defines as two or more persons agreeing to act in concert in pursuit of a common goal<br>
</ref>

There must be an "intention to agree, the completion of an agreement and a common design."<ref>
''United States of America v Dynar'', [http://canlii.ca/t/1fr0t  1997 CanLII 359], [1997] 2 SCR 462{{perSCC|Cory and Iacobucci JJ}}{{atL|1fr0t|86}}<br>
''R v Root'', [http://canlii.ca/t/2200k 2008 ONCA 869] (CanLII), [2008] OJ No 5214 (OCA){{perONCA|Watt JA}}{{atL|2200k|66}}</ref>
The Crown needs only prove that there was "a meeting of the minds with regard to a common design to do something unlawful".<ref>
{{supra1|Dynar}}{{atL|1fr0t|87}}</ref>

To prove conspiracy the facts must satisfy a three-part Carter test:<ref>
''R v Carter'', [http://canlii.ca/t/1z1c7 1982 CanLII 35], [1982] 1 SCR 938{{perSCC|McIntyre J}}</ref>
# has the Crown proven beyond a reasonable doubt the existence of the conspiracy?
# has the Crown proven that the accused was probably a member of the conspiracy?
# considering all of the evidence, is the accused guilty beyond a reasonable doubt of being a member of the conspiracy?

A conspiracy must include (1) an agreement and (2) the unlawful objective or "common design".<ref>
{{supra1|O'Brien}}{{atsL|21v9k|2| to 3}}, ("It is of course, essential that the conspirators have the intention to agree, and this agreement must be complete ... there must exist an intention to put the common design into effect.")<br>
''R v Root'', [http://canlii.ca/t/2200k 2008 ONCA 869] (CanLII){{fix}}
</ref>

As well, unlawful objective does not need to come about. It is the planning that is the criminal act.<ref>
{{supra1|O'Brien}}{{atL|21v9k|4}} ("The law punishes conspiracy so that the unlawful object is not attained. It considers that several persons who agree together to commit an unlawful act, are a menace to society, and even if they do nothing in furtherance of their common design, the state intervenes to exercise a repressive action, so that the intention is not materialized, and does not become harmful to any one.")
</ref>

A conspiracy made over the telephone will occur within the jurisdiction of both calling parties.<ref>
''R v Doucette'', [http://canlii.ca/t/5cq6 2003 PESCAD 7] (CanLII), ''per'' Mitchell CJ</ref>

Both legal and factual impossibility are not defences to an allegation of conspiracy.<ref>
{{supra1|Dynar}}{{atL|1fr0t|105}} (It is not relevant whether "from an objective point of view, commission of the offence may be impossible.")</ref>

It is not necessary to prove that the predicate offence was actually committed.<ref>
See ''R v Koufis'', [http://canlii.ca/t/fsmws 1941 CanLII 55] (SCC), [1941] SCR 481, 76 CCC 161 (SCC){{perSCC|Taschereau J}}<br>
''R v Beaven'', [http://canlii.ca/t/fvz5s 2013 SKQB 7] (CanLII){{perSKQB|Rothery J}}{{atL|fvz5s|73}}<br>
</ref>

The fact that the co-conspirators are unidentified does not result in a failure to prove the offence of conspiracy.<ref>
{{supra1|Root}}{{atL|2200k|69}}</ref>

{{reflist|2}}

===Agreement===
The agreement is the essence of the offence of conspiracy.<ref>
''R v Papalia'', [http://canlii.ca/t/1tx7p 1979 CanLII 38] (SCC), [1979] 2 SCR 256{{perSCC|Dickson J}} ("The essence of criminal conspiracy is proof of agreement...")
</ref>

An agreement can be implied or tacit. It requires a meeting of the minds to create a common intention to commit an offence.
The parties must have knowledge of a common goal and agreement to achieve it.<ref>
''Atlantic Sugar Refineries Co. v Canada (Attorney General)'', 54 CCC (2d) 373, [http://canlii.ca/t/1z493 1980 CanLII 226] (SCC), [1980] 2 SCR 644{{perSCC|Pigeon J}}</ref>

There must be a "consensus to effect an unlawful purpose".<ref>
{{supra2|1tx7p|Papalia}} (“two or more persons pursued the same unlawful object at the same time or in the same place; it is necessary to show a consensus to effect an unlawful purpose. ”)<br>
</ref>

It is not enough that there be a common intention.<ref>
''R v O'Brien'', [http://canlii.ca/t/21v9k 1954 CanLII 42], [1954] SCR 666{{perSCC|Taschereau J}}</ref> 
Nor is passive acquiescence to a criminal plan sufficient<ref>
''R v McNamara'' (1981), 56 CCC (2d) 193 at 452 (Ont. C.A.), [http://canlii.ca/t/gd1kv 1981 CanLII 3120] (ON CA){{TheCourtONCA}} ("Mere knowledge of, discussion of or passive acquiescence in a plan of criminal conduct is not, of itself, sufficient")
</ref>
, knowledge of the plan<ref>
Goode, Criminal Conspiracy in Canada (1975), p. 16</ref>
, or nor wilful blindness.

It is not a "formal agreement" and may be implicit.<ref>
Goode, Criminal Conspiracy in Canada (1975), p. 16<br>
</ref>

Where there is a pre-existing conspiracy, the accused must have adopted it or consented to participate in achieving the goal.<ref>
''R v Lamontagne'', [http://canlii.ca/t/1mw17 1999 CanLII 13463] (QC CA), (1999), 142 CCC (3d) 561 (Que. C.A.), [http://canlii.ca/t/1mw17 1999 CanLII 13463] (QC CA){{TheCourt}}
</ref>

A conditional agreement can still be an agreement.<ref>
''R v Root'', [http://canlii.ca/t/2200k 2008 ONCA 869] (CanLII){{perONCA|Watt JA}}{{atL|2200k|70}}</ref>

The charge must identify the crime(s) planned.<ref>
''R v Saunders'', [http://canlii.ca/t/1fsvd 1990 CanLII 1131] (SCC), [1990] 1 SCR 1020{{perSCC|McLachlin J}}</ref>
And it should generally identify the co-conspirators.<ref>
''R v TLB'' (1989), 52 CCC (3d) 72 (NSCA), [http://canlii.ca/t/g97pz 1989 CanLII 7210] (NS CA){{perNSCA|Hart JA}}<br>
{{supra1|Root}}{{atL|2200k|69}}</ref>

It is a valid defence to establish that the accused pretended to agree to the conspiracy.<ref>
''R v Delay'' (1976), 25 CCC (2d) 575 (Ont. C.A.), [http://canlii.ca/t/htwxc 1976 CanLII 1409] (ON CA){{perONCA|Jessup JA}}</ref>

The trier of fact must find "that the accused intended to enter into the agreement".<ref>
''R v Barbeau'', [http://canlii.ca/t/1njv8 1996 CanLII 6391] (QC CA){{atp|568}}<br>
</ref>

Conspiracy cannot be committed by way of an accused being reckless as to the object of the agreement.<ref>
''R v Lessard'' (1982), 10 CCC (3d) 61 (QCCA), [http://canlii.ca/t/gckh4 1982 CanLII 3814] (QC CA){{perQCCA|Bisson JA}}{{atp|86}}<br>
{{supra1|Lamontagne}}{{atp|576}} "one notes that the crime of conspiracy cannot be committed by mere recklessness as to the object of the agreement")<br>
</ref> 
However, the accused can be liable where he is reckless as to the method of execution of the agreement.<ref>
{{supra2|1njv8|Barbeau}}<br>
''R v Park'', [http://canlii.ca/t/2524l 2009 ABQB 470] (CanLII){{perABQB|Ouellette J}} ("recklessness may only be applied with respect to the method of execution of the agreement")<br>
{{supra1|Lessard}}<br>
{{supra1|Lamontagne}}<br>
</ref>

Willful blindness can satisfy the ''mens rea'' requirement of conspiracy.<ref>
{{supra2|1njv8|Barbeau}}<br>
{{supra2|2524l|Park}} ("The ''mens rea'' requirement for conspiracy may be satisfied where willful blindness is established")<br>
</ref>

A party to an offence, including conspiracy "must have some knowledge of the essential nature of the offence to be committed, but not necessarily knowledge of all the details".<ref>
{{supra2|2524l|Park}}{{atps|569 to 571}}<br>
</ref>

Evidence of "how" the agreement is to be carried out, specifically to over acts to be taken are elements to the agreement element of the offence.<ref>
''R v Douglas'', [1991] 1 SCR 301, [http://canlii.ca/t/1fsnr 1991 CanLII 81] (SCC){{perSCC|Cory J}}{{atL|1fsnr|28}} ("How that agreement is to be  carried out, that is to say, the steps taken in furtherance of the agreement (the overt acts) are simply elements going to the proof of the essential ingredient of the offence, namely the agreement.")
</ref>

{{Reflist|2}}

===Common Design===
There must be a "a common plan with a common objective".<ref> 
''R v Cotroni'', (sub nom. Papalia), [http://canlii.ca/t/1tx7p 1979 CanLII 38] (SCC), [1979] 2 SCR 256{{perSCC|Dickson J}}
</ref>

The Crown must establish that the accused had an intention to become a party to the common design with the knowledge of its implications.<ref>
{{supra1|Papalia}} (“In addition to proof of common design, it was incumbent on the Crown to establish that each accused had the intention to become a party to that common design with knowledge of its implications.”)
</ref>

{{reflist|2}}

===Participation===
It is not required that it be proven that every member of the conspiracy be involved in its execution or that they were involved throughout the entire time. It is enough if the evidence "demonstrates that the conspiracy proven included some of the accused; establishes that it occurred at some time within the time frame alleged in the indictment; and had as its object the type of crime alleged."<ref>
''R v Douglas'', [1991] 1 SCR 301, [http://canlii.ca/t/1fsnr 1991 CanLII 81] (SCC){{perSCC|Cory J}}{{atL|1fsnr|41}}<br>
Papalia ("The essence of criminal conspiracy is proof of agreement...")<br>
</ref>

A member of a conspiracy who refuses to execute the plan is still guilty.<ref>
''R v O'Brien'', [http://canlii.ca/t/21v9k 1954 CanLII 42], [1954] SCR 666{{perSCC|Taschereau J}}{{atL|21v9k|4}}
</ref>

Involvement in only part of a whole plan will still be found guilty.<ref>
''R v Shirose'', [http://canlii.ca/t/1fqp4 1999 CanLII 676] (SCC), [1999] 1 SCR 565{{perSCC|Binnie J}}</ref>

An accused cannot be convicted for attempted conspiracy.<ref>
''R v Dery'', [http://canlii.ca/t/1q1hs 2006 SCC 53] (CanLII), [2006] 2 SCR 669{{perSCC|Fish J}} </ref>

{{Reflist|2}}

===Evidence===
Words of the co-conspirator are admissible against the accused. They are not hearsay and are rather the actus reus.<ref> 
''R v Cook'' (1984), 39 C.R. (3d) 300 (ONCA) aff'd in [http://canlii.ca/t/1ftv8 1986 CanLII 47] (SCC), [1986] 1 SCR 144{{perSCC|Dickson CJ}}</ref>

Further, the co-conspirators exception to hearsay makes statements admissible against the accused.<ref>
''R v Gassyt'' (1998), 127 CCC (3d) 546 (ONCA), [http://canlii.ca/t/6h3c 1998 CanLII 5976] (ON CA){{perONCA|Charron JA}}<br>
''R v Perciballi'' (2001), 154 CCC (3d) 481 (Ont. C.A.), [http://canlii.ca/t/1fbs7 2001 CanLII 13394] (ON CA){{perONCA|Charron JA}} aff'd in [http://canlii.ca/t/51ss 2002 SCC 51] (CanLII){{perSCC|McLachlin CJ}}<br>
''R v Gagnon'' (2000), 147 CCC (3d) 193 (ONCA), [http://canlii.ca/t/1fbc2 2000 CanLII 16863] (ON CA){{perONCA|Weiler JA}}<br>
</ref>

Statements by the co-conspirator that are not related to the conspiracy are not admissible against the accused.<ref>
''R v Henke'', [http://canlii.ca/t/2dr7n 1989 ABCA 263] (CanLII), (1989), 72 C.R. (3d) 395 (Alta C.A.){{TheCourt}}<br>
''R v Maugey'', [http://canlii.ca/t/1fb79 2000 CanLII 8488] (ON CA), (2000), 146 CCC (3d) 99 (Ont. C.A.){{perONCA|Feldman JA}}<br>
</ref>

{{reflist|2}}

===Aiding and Abetting===
{{seealso|Parties to an Offence}}

There has been a divided line of case law on whether a conviction can be made for being a party to a conspiracy.<ref>
''R v Park'', [http://canlii.ca/t/2524l 2009 ABQB 470] (CanLII){{perABQB|Ouellette J}}{{atps|540 to 575}}<br>
''R v Taylor'' (1984), 40 C.R. (3d) 222 (BCSC){{NOCANLII}}<br>
</ref>

The members of a conspiracy do not need to all play an equal role in the endeavour, nor do they need to personally commit the offence they have agreed. Any degree of assistance can create membership.<Ref>
''R v JF''', [2013] 1 SCR 565, [http://canlii.ca/t/fwb36 2013 SCC 12] (CanLII){{atL|fwb36|54}} (...it is not necessary that all members of a conspiracy play, or intend to play, equal roles in the ultimate commission of the unlawful object.  Indeed, members in a conspiracy need not personally commit, or intend to commit, the offence which each has agreed should be committed:... Any degree of assistance in the furtherance of the unlawful object can lead to a finding of membership as long as agreement to a common plan can be inferred and the requisite mental state has been established.")<br>
</ref>

{{reflist|2}}

===Jurisdiction===

{{quotation|
465.<br>...
<br>
; Conspiracy to commit offences
(3) Every one who, while in Canada, conspires with any one to do anything referred to in subsection (1) in a place outside Canada that is an offence under the laws of that place shall be deemed to have conspired to do that thing in Canada.
; Idem
(4) Every one who, while in a place outside Canada, conspires with any one to do anything referred to in subsection (1) in Canada shall be deemed to have conspired in Canada to do that thing.
; Jurisdiction
(5) Where a person is alleged to have conspired to do anything that is an offence by virtue of subsection (3) or (4), proceedings in respect of that offence may, whether or not that person is in Canada, be commenced in any territorial division in Canada, and the accused may be tried and punished in respect of that offence in the same manner as if the offence had been committed in that territorial division.
; Appearance of accused at trial
(6) For greater certainty, the provisions of this Act relating to
:(a) requirements that an accused appear at and be present during proceedings, and
:(b) the exceptions to those requirements,
apply to proceedings commenced in any territorial division pursuant to subsection (5).
; If previously tried outside Canada
(7) If a person is alleged to have conspired to do anything that is an offence by virtue of subsection (3) or (4) and that person has been tried and dealt with outside Canada in respect of the offence in such a manner that, if the person had been tried and dealt with in Canada, they would be able to plead autrefois acquit, autrefois convict, pardon or an expungement order under the Expungement of Historically Unjust Convictions Act, the person shall be deemed to have been so tried and dealt with in Canada.

R.S., {{LegHistory80s|1985, c. C-46}}, s. 465;
R.S., {{LegHistory80s|1985, c. 27 (1st Supp.)}}, s. 61;
{{LegHistory90s|1998, c. 35}}, s. 121;
{{LegHistory10s|2018, c. 11}}, s. 28;
{{LegHistory10s|2019, c. 25}}, s. 183
|[{{CCCSec|465}} CCC]
}}

===Defences===
{{quotation|
; Saving
467 (1) No person shall be convicted of the offence of conspiracy by reason only that he
:(a) refuses to work with a workman or for an employer; or
:(b) does any act or causes any act to be done for the purpose of a trade combination, unless that act is an offence expressly punishable by law.

; Definition of trade combination
(2) In this section, trade combination means any combination between masters or workmen or other persons for the purpose of regulating or altering the relations between masters or workmen, or the conduct of a master or workman in or in respect of his business, employment or contract of employment or service.
<br>
R.S., c. C-34, s. 425.
|[{{CCCSec|467}} CCC]
}}

==Participation of Third Parties==
{{seealso|Role of the Victim and Third Parties|Testimonial Aids for Young, Disabled or Vulnerable Witnesses}}

; Testimonial Aids
{{3rdPTestimonyAids}}

; On Finding of Guilt
<!--
{{606Notice5Y|XX}}
{{606NoticeSPIO|XX}}
-->
{{RestitutionNotice}}

{{VISNotice}}

==Sentencing Principles and Ranges==

; Maximum Penalties
{{SProfileMaxHeader}}
{{SProfileMax|s. 465(1)(a) {{DescrSec|465(1)(a)}} | {{NA}} | {{MaxLife}} }}
{{SProfileMax|s.  465(1)(b)(i) {{DescrSec| 465(1)(b)(i)}} | {{NA}} | {{Max10Years}} }}
{{SProfileMax|s.  465(1)(b)(ii) {{DescrSec| 465(1)(b)(ii)}} | {{NA}} | {{Max5Years}} }}
{{SProfileMax|s.  465(1)(d) {{DescrSec| 465(1)(d)}} | {{NA}} | {{MaxSummary}} }}
{{SProfileEnd}}

{{MaxPenaltyIndictment|s. 465(1)(a), (b), and (c)|'''life''' under s. 465(1)(a), '''10 years incarceration''' under s. 465(1)(b)(i), and '''5 years incarceration''' under s. 465(1)(b)(ii)}} Where prosecuted under s. 465(1)(c) the maximum penalty will match that of the index offence.

{{MaxPenaltySummary|s. 465(1)(d)|'''{{summaryconviction}}'''}}

; Minimum Penalties
{{NoMinimumPenalties}}

; Available Dispositions
{{SProfileAvailHeader}}
|s. 465(1)(a) {{DescrSec|465(1)(a)}} || {{NA}} || {{SProfileNoDischargeOrCSO}}
|-
|s. 465(1)(d) {{DescrSec|465(1)(d)}}|| {{NA}} || {{SProfileAll}}
|-
{{SProfileEnd}}
{{NoDischargeAvailable|s. 465(1)(a)}}

{{NoCSOAvailable|C|s. 465(1)(a)}}

; Consecutive Sentences
{{NoConsecutive}}

==Ancillary Sentencing Orders==
{{seealso|Ancillary Orders}}
	
; Offence-specific Orders
* Varies based on index offence
{{AOrderHeader}}
| [[DNA Orders]] ||s. 465(1)(b)(i), (ii) ||
* {{SecondDNA(AorB)|s. 465(1)(b)(i),(ii)}}
|-
| [[Delayed Parole Eligibility|Delayed Parole Order]] ||s. 465(1)(a) {{DescrSec|465(1)(a)}} ||
* {{ParoleDelayEligible|1|s. 465(1)(a) [conspiracy to commit murder]}}
|}
; General Sentencing Orders
{{GeneralSentencingOrders}}

; General Forfeiture Orders
{{GeneralForfeitureOrders}}

==See Also==
* [[Parties to an Offence#Counselling]]