'We think it obvious that Lord Bridge cannot have been intending that the organiser of a crime who recruited others to carry it out would not himself be guilty of conspiracy unless it could be proved that he intended to play some active part himself thereafter. The nub of the offence of conspiracy consists of the agreement to do the unlawful act, and that may mean that you are doing it yourself actively or that you are agreeing that somebody else should do it actively. In either event, you are guilty of conspiracy.' (Per O'Connor LJ.)
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