A well-known example of an obvious point is
Thornton v Mitchell  1 All ER 339
The charge is against P who is the driver of a double decker bus. D is the conductorof this bus. Because of the way the vehicle is constructed, there is a large blind spotwhen the bus is being reversed. And so, while reversing, P was dependent on thedirections given by D the conductor.Because of the carelessness of the conductor, unfortunately a pedestrian, V, is runover by the bus. On the basis of this, both P and D are charged with the offence of careless driving.P is the driver of the bus. Careless driving clearly requires an act of driving. Theoffence in a question is clearly a conduct offence. The
requires carelessdriving; that which falls below the standard of an ordinary prudent driver. There is no
in this case however. The driving of the vehicle is perfectlyacceptable on the part of P. He couldn’t see for himself and it was perfectlyreasonable for him to rely on the instructions of D. That’s a bonus for D becausewithout any careless driving, there is no offence for D to be an accomplice to.So
stands for the proposition that at least an
is required. Should we sometimes be content with just the
though? Can we dilute theorthodoxy and say if we’ve got the
of an offence ( say a d eath, which isclearly unlawful,) and say that provided we have an
, we can deal witheach individual with regards to this death based on his own
If D had the mens rea for murder, he can be convicted of murder (of complicity formurder as it were) and if P had diminished responsibility for some reason, he can beconvicted of manslaughter.
Richards  QB 776
. (Clinging to the pure doctrine is a bit unfair as to justicemeted out)D wants her husband beaten up. She prevails upon 2 men to carry out her wishes.She essentially says ‘I want him beaten up sufficiently to put him in hospital for along time’.So she has the
for causing GBH with intent to cause GBH. P1 and P2 getthere, and seriously hurt V. So you’ve got your GBH.