DAMODARAM SANJIVAYYA NATIONAL LAW UNIVERSITY

VISAKHAPATNAM, A.P., INDIA

SUBJECT
LAW OF CRIMES

PROJECT TITLE

CRIMINAL CONSPIRACY

Submitted by:

ASHIRBAD SAHOO(2019082)

CERTIFICATE

TITLE OF SUBJECT: Law of Crimes

NAME OF FACULTY: Dr Bhavani Prasad Panda

I ASHIRBAD SAHOO hereby declare that this project is about CRIMINAL CONSPIRACY: . Submitted by me is an original work undertaken
by me. I have duly acknowledged all the sources from which the ideas and extracts have been taken. The project is free from any plagiarism issue.

PLACE: Vishakhapatnam.
TABLE OF CONTENTS

INTRODUCTION

ESSENTIALS

INGREDIENTS

SECTION 120A

CASE LAWS

SECTION 120 B

CONCLUSION

BIBLIOGRAPHY

ABSTRACT

Introduction:

An agreement between two or more persons to engage jointly in an unlawful or criminal act, or an act that is innocent in itself but becomes
unlawful when done by the combination of actors. conspiracy is governed by statute in federal courts and most state courts. Before its
codification in state and federal statutes, the crime of conspiracy was simply an agreement to engage in an unlawful act with the intent to carry
out the act. Federal statutes and many statutes now require not only agreement and intent but also the commission of an over act in furtherance of
the agreement. Conspiracy is a crime separate from the criminal act for which it is developed.

For example: One who conspires with another to commit burglary and in fact commits the burglary can be charged with both conspiracy to
commit burglary and burglary.

Conspiracy is an inchoate, or preparatory, crime. It is similar to solicitation in that both crimes are committed by manifesting an intent to engage
in a criminal act.
Scope and Limitation:

The scope of the project is to deal with the criminal conspiracy and the and the judgement of the other countries.

Objective:

The objective of the study is to deal with the criminal conspiracy and independent people in the project.

Literature Review: The researcher has taken help of various books, articles and various websites. All the sources used by the researcher are
primary sources.

Citation: Citation: 35 Harvard Law Review 393 1921-1922

Authors: Francis B. Sayre.

Summary:

In this article the author states that the criminal conspiracy lends no strength or glory to the law. The origin of the crime of conspiracy goes back
to the very early pages of the history of our common law. During the thirteenth century, according to Bracton,3 there were two modes of
commencing prosecution for felonies the one, by way of private appeal, generally involving trial by battle, and the other by way of public
inquest before what later developed into the grand jury. Nevertheless, abuses sprang up children under twelve, who could not be outlawed and
against whom no damages could be recovered, were sometimes incited to bring the appeal. "Conspirators be they that do confider or bind
themselves by Oath, Covenant, or other Alliance, that every of them shall aid and support the enterprise.

The record of a case decided in the court was called upon to decide whether the offense of conspiracy could be so broadened as to include
combinations to commit acts of a generally illegal and oppressive nature. In the Poulterers' Case, the defendant poulterers had confederated to
bring against one, Stone, a false accusation of robbery; but Stone was so manifestly innocent of the crime charged that the grand jury refused to
indict him. In the ancient phraseology, it was not necessary to show that anything had been "put in ure"; 17 the mere conspiracy alone was held
to constitute the gist of the offense and to be therefore indictable.

Citation: 72 Harv. L. Rev. 920 1958-1959 , Hardward law Review

With the growth of organized criminal activity the conspiracy indictment has become an increasingly important weapon in the prosecutor's side.
In some cases the criminal conspiracy serves to nullify the opportunities for escaping punishment that the defendant might otherwise obtain from
the punishment of his position within a group or from the difficulty of tracing his precise contribution to any given substantive offense.
Conspiracy is usually defined as an agreement between two or more persons to achieve an unlawful object or to achieve a lawful object by
unlawful means. In any event, a comparably broad doctrine of conspiracy has not emerged in civil-law countries. However, as action toward a
criminal end nears execution, a point is reached at which the increasing risk to society is thought to outweigh the diminishing likelihood of a
change of heart or of a misreading of intent, and at this point mere "preparation" becomes punishable as "attempt." A conspirator who has
committed himself to support his associates may be less likely to violate this commitment than he would be to revise a purely private decision.
There are some elements in the criminal conspiracy that are The Act of Agreement, The Party Dimension, The Object Dimension etc.

Case Laws:

State of tamilnadu through superintendent of police, cbi sit v Nalini and others

R.P Dewagan vs state of Madhya Pradesh 2002

 CHAPTER-I

Introduction:-

Criminal conspiracy is an agreement between two or more persons formed for the purpose of committing a crime. The application and to the
evidence necessary to prove the existence of the agreement. Criminalization of conspiracy performs two functions. The first function is that
performed by any inchoate offense-the interruption of criminal activity prior to its completion. At least in theory, conspiracy subjects the
defendant to criminal sanctions at a stage earlier than any other offense, even attempt. "[Every criminal conspiracy is not an attempt. One may
become guilty of conspiracy long before his act has come so dangerously near to completion as to make him criminally liable for the attempted
crime." The courts rarely have stated the rationale for this early sanction, although a few commentators have offered justifications for it, arguing
that individuals who band together have expressed, immediately upon their agreement, a clear intent to violate society's laws. Also, it is argued
1
that when more than one person agrees to engage in the criminal activity, the likelihood of the accomplishment of the crime is increased.

The effort of an individual to disturb this equilibrium can never be perceptible, nor carry the operation of his interest on that of any other
individual, beyond the limits of fair competition; but the increase of power by combination of means, being in geometrical proportion to the
number concerned, an association may be able to give an impulse, not only oppressive to individuals, but mischievous to the public at large; and
it is the employment of an engine so powerful and dangerous, that gives criminality to an act that would be perfectly innocent, at least in a legal
view, when done by an individual.'

Conspiracy is a crime at the moment the agreement is formed, or at the moment some minor act is taken in furtherance of that agreement. This is
an earlier stage of criminal activity than is required for attempt, which usually involves either a substantial step toward the commission of the
contemplated crime, or else "conduct that, in fact, amounts to more than mere preparation for, and indicates intent to complete, the commission
of the crime. Regardless of whether attempt could handle the inchoate conspiracy activities in theory, or whether it would be desirable, attempt
would seem to be able to handle those situations in which prosecutors actually charge conspiracy. Conversations with prosecutors confirmed
this. One stated that "[no one will prosecute a case without an overt act; generally there is at least an attempt unless you have an informant which
is the rare situation, for you find out about the conspiratorial relationship from the overt act."

A conspiracy consists not merely in the intention of two or more, but in the agreement of two or more to do an unlawful act, or to do a lawful act
by unlawful means. So long as such a design rests in intention only it is not indictable. When two agree to carry it into effect, the very plot is an
act in itself, and the act of each of the parties, promise against promise, actus contra actum, capable of being enforced, if lawful, punishable of
for a criminal object or for the use of criminal means.

Ingredients of criminal conspiracy:

Unlawful agreement :

It is an element of a criminal conspiracy.  Generally, the crime of conspiracy is complete when parties enter into a conspiratorial agreement. 
Moreover, if there is an agreement between two or more persons for an unlawful purpose, it is considered a criminal conspiracy even where
there is no agreement regarding the details of the criminal scheme or the means by which the unlawful purpose will be accomplished.   The
agreement will determine whether single or multiple conspiracies exist between the parties.  A single conspiratorial agreement will constitute a
single criminal conspiracy and multiple agreements to commit separate crimes will constitute multiple conspiracies.

1
scholarship.law.wm.edu/cgi/viewcontent.cgi?article=1636&context..
Similarly, conspiracy is considered a specific intent crime.  A specific intent crime is one in which a person acts with knowledge of what he/she
is doing and also with the objective of completing some unlawful act.  The intent can be determined from words, acts, and conduct.  If the
conspirators agree or conspire with specific intent to kill and commit an overt act in furtherance of such agreement, then they are guilty of
conspiracy to commit express malice murder.2

knowledge:-

  To be more specific, to make a person liable for criminal conspiracy as a co conspirator, he/she must have knowledge of the existence of the
conspiracy and knowledge of the illegal object of the conspiracy.  At the same time, a person having no knowledge of a conspiracy cannot be
considered a conspirator.

Similarly, in order to satisfy the statute, the government must prove that a conspirator committed an overt act in furtherance of the conspiracy.  A
conspiracy conviction requires proof of the commission of at least one overt act by one of the conspirators within the five-year statutory period
in furtherance of the conspiratorial agreement.3

CHAPTER-II

Section 120-A of the I.P.C. defines ‘conspiracy’ to mean that when two or more persons agree to do, or cause to be done an illegal act, or an act
which is not illegal by illegal means, such an agreement is designated as “criminal conspiracy.

No agreement except an agreement to commit an offence shall amount to a criminal conspiracy, unless some act besides the agreement is done
by one or more parties to such agreement in furtherance thereof.

The main thing on which criminality lies under this section is the “agreement”, which requires at least two persons. Here ‘Agreement’ is not
merely the stage of intention which is not culpable, but is much more than that.

It is a plan or a design to bring in action. The plot is an act in itself. It is not necessary that all the members of the conspiracy must be aware of
each detail of the conspiracy, but it is essential and required that there has to be a common design among them and every conspirator  from his
end of the design must carry out into effect or execute the plan.

However, every conspirator will be aware of the major and important details of the conspiracy if not the minutest details.

For example- If there is a conspiracy of committing a murder amongst some persons, each of the conspirator will have to be aware of the major
detail of the conspiracy in order to execute the plan properly. Major details here would be,  who is to be murdered and how, when he is to be
murdered and by whom, even though the other minute details might not be known to each of them.

In determining criminal conspiracy it is immaterial whether the ultimate object of the agreement is such illegal act or not. A conspirator to
commit an offence punishable with death imprisonment for life or rigorous imprisonment for a term of two years or upward and no specific
provision is made for such conspiracy then the offender will be punished in the same manner as he has abetted the offence. If the conspiracy is
not to commit an offence then the provided punishment shall be term not exceeding six months or fine or both.

It is important that the culpability of an offence is inconsonance with the degree or grade of the act of perpetrator, while determining the guilt of
the accused persons, the degree and the act of the participants in the offence has to be carefully and cautiously assessed.

ELEMENTS OF THE CRIME:

The Act of Agreement. -

2
Ajeet Singh Chauhan and others v State of U.P. and others

3
State of Delhi v Bashir Ahmed Ponnu and others
Although every other common-law crime includes both a criminal act and a criminal intent, it has been contended that the law of conspiracy
punishes intent alone. Such a view seems unjustified. In its early development the crime might have been explained by considering its criminal
act to be the physical act of communicating, by words or otherwise, mutual adherence to a common enterprise; for originally the statute of
limitations began to run on a conspiracy as soon as this communication was made. Today, however, it is established that conspiracy is a
continuing crime, extending beyond the initial communication of agreement. It seems, therefore, that the criminal act of the modern crime is not
the communication of agreement, but the act of agreement itself, that is, the continuous and conscious union of wills upon a common
undertaking.

While this act is not physical, it still goes beyond the completely internal and subjective act of intending. It requires on the part of each
conspirator communion with a mind and will outside himself, and it must be initiated by a communication of common intention and assent
through physical means. If some principle of law demands that the line of criminal responsibility never be drawn short of a physical act, the act
of agreeing should go unnoticed. But the line the common law has chosen does not seem irrational. "Indeed, it seems a reduction to absurdity,
that procuring a single stand of arms should be a sufficient overt act to make the disloyal design indictable, and that conspiring with a thousand
men to enlist should not."

The Criminal Intent:-

In actuality, conspiracy defies division into the classic elements of criminal act and criminal intent, since the act, being volitional, includes
within itself the intent. For purposes of analysis, however, the division remains meaningful. Therefore, this section is devoted to a second
consideration of intent, this time apart from its function as an element necessary to the commission of the criminal act, and in its role as the mens
rea required for criminal guilt under the common law' Specific Intent. - It has been said that conspiracy requires "specific intent." This phrase is
properly used to denote something more than merely a corrupt or wrongful purpose; it indicates a particular kind of purpose characteristic of the
particular "species" of crime. Larceny, for example, requires the specific intent to deprive someone of his property permanently. The intent to
deprive him of it only temporarily, while it may be corrupt and wrongful, will not support a conviction 4. It has been observed that there are
really two intents required for the crime of conspiracy: an intent to agree and an intent to achieve the object of the agreement. As applied to the
former, the statement that conspiracy requires a specific intent is clearly correct, for the intent to agree is indispensable to, and characteristic of,
this species of crime. But if the statement is meant to apply to the second intent, as appears to be the case, it seems inaccurate. It is difficult, in
fact, to conceive of any crime in which the intent is less specific.

Wrongful Intent. -

A question of more practical significance than whether the intent in the crime of conspiracy is specific is whether it need be wrongful, that is,
whether any mens rea need be shown at all. The view which has won general acceptance in this country was first proposed in People v. Powell
and was later well expressed by Justice Qua in Commonwealth v. Benesch: "In the case of conspiracy, as with other common law crimes, it is
necessary that criminal intent be shown. Speaking in general terms, there must be an intent to do wrong." If the act that is conspired to is malum
in se, this intent merely requires knowledge of the relevant facts, so that the parties know what they are planning; but if it is an act not wrongful
in itself and merely made unlawful by statute, the requisite intent to do wrong does not exist without knowledge that the contemplated acts
violate the law. Therefore, even when the commission of a particular substantive offense does not require scienter, conspiracy to commit that
offense does. Such a view seems consistent with the general-danger rationale of conspiracy, since it is difficult to say that a grouping is
inherently antisocial and poses a continuing threat merely because a contemplated act which it thinks to be lawful is in fact unlawful. It may be
argued that if the group plans such an act once, it may do so again, and so does constitute a continuing danger. But merely informing the group
of the illegality of its object, rather than invoking the severe sanction of criminal punishment, may be all that is necessary to end such danger. If
this is not effective, then the group in its subsequent activity will possess the requisite scienter, and so will be antisocial and punishable as a
conspiracy.

4
N. Ratnakumari v State of Odisha and others
Objects:-

General Nature.-

A famous maxim states that an indictment "ought to charge a conspiracy, either to do an unlawful act, or a lawful act by unlawful means." In
practice no real distinction has been drawn between ends and means. Whether or not this clause is a "magic jingle" which obviates "the necessity
of correctly analyzing the doctrine of conspiracy" seems open to question. 'The precise limits of the word "unlawful" are unclear. There seems
to be general agreement that an indictable conspiracy exists whenever the object to be attained is felonious. Conspiracy convictions may be
sustained when the object of the conspiracy is a misdemeanour, even when the penalty for conspiring is much more severe than the penalty for
the substantive offense.' Furthermore, when the object of the conspiracy is itself unlawful only in the sense that liability for civil damages may
result, and even when attainment of the object intended involves no civil or criminal sanctions, conspiracy convictions are allowed.

Requisite Plurality:-

Husband and Wife:-

Criminal conspiracy requires a plurality of conspirators. At common law husband and wife were one. Thus the rule was early established that
husband and wife cannot be counted as the minimum two parties necessary to make up a criminal conspiracy.' The rule, accepted initially by
American courts as the common law, was first questioned early in this century.' However, it was not expressly repudiated by a state court until
and not by a federal court until Some earlier courts may have applied the common-law rule on the basis of the ancient doctrine that the wife
was not liable for substantive offenses committed jointly with her husband because she was presumed to be under his control. Any presumption
of control sufficient to defeat a finding of plurality has been much weakened. In the other cases in which the rule has been accepted, it seems to
have been mechanically applied; similarly, when rejected, it has been mechanically rejected. The courts in the latter cases simply note that in no
other field of modern law are husband and wife considered one.

At one time it was held that corporations could not be indicted for offenses requiring criminal intent. However, a corporation is now indictable
as a conspirator, arguably for the reason that the intent of agents who conspire is imputed to the corporation. However, as in situations involving
husband and wife, problems in determining the existence of the plurality necessary for indictment arise. When two corporations and an officer of
each are indicted, the necessary plurality is evident. It is also apparent when a corporation, one of its officers, and a third person combine for
unlawful ends. When, however, the corporate entity and a single agent are the only two parties to a conspiracy, plurality seems lacking; and there
appears to be no conspiracy for which intent is imputable to the corporation.

The Wharton Rule. -

A defendant can be convicted of conspiracy although his co-conspirators are immune from prosecution both for the conspiracy and for the
substantive offense, but not when his co-conspirators are without legal capacity. Moreover, a defendant can be convicted of conspiring to
commit a substantive offense for which he himself is not indictable. The latter rule is upheld against the charge that it is contrary to legislative
intent on the ground that the conspiracy is "distinct" from the substantive offense. 5Although this merely states the conclusion, the rule appears to
be sound in view of the rationales underlying conspiracy. The substantive offense seems more likely to be accomplished once the agreement is
made, and in any event, a combination dangerous in itself, no matter who is liable for the substantive offense, introduces the normal general
dangers of conspiracy. The argument that the legislature intended to punish only the party who can actually commit the substantive offense has
force only when the party indicted for conspiring is a member of a legislatively protected class. However, even in such a case, a conspiracy
conviction was sustained when the protected person was extraordinarily active in pursuing the criminal object.

5
N. Ratnakumari v State of Odisha and others
.

CHAPTER-IV

Case Law:

Bimbadhar Pradhan vs The State Of Orissa on 13 March,

The appellant and four others were placed on their trial before the Assistant Sessions Judge of Sambalpur for offences under sections 120-
B, 409,477-A and 109, Indian Penal Code with having committed the offences of criminal conspiracy, criminal breach of trust in respect of
Government property, and falsification of accounts with a view to defraud the Government. The appellant was the District Food Production
Officer in Sambalpur and the other four accused persons were agricultural sub-overseers in charge of their respective areas under the appellant.
Another such agricultural sub-overseer was Pitabas Sahu at Bargarh centre. He was examined at the trial as P.W. 25 and (1) (1955) 2 S.C.R. 881

The prosecution case is that in furtherance of the Grow More Food Scheme initiated by Government it was decided to subsidize the supply of oil
cake to agriculturists with a view to augmenting the production of food crops. Cultivators were to be supplied this variety of manure at Rs. 440
per maund, though the Government had to spend per maund. The appellant entered into a conspiracy with his subordinate staff including the
agricultural sub- overseers aforesaid to misappropriate the funds thus placed at their disposal for the procurement and supply of oil cake to
cultivators. To bolster up the quantity of oil cakes to be procured, they showed false transactions of purchase and distribution thereof and
falsified accounts, vouchers, etc. Thus they were alleged to have misappropriated of Government money.

A large volume of oral and documentary evidence was adduced on behalf of the prosecution. The three assessors who assisted at the trial were of
the opinion that none of the accused was guilty. The learned Assistant Sessions Judge in agreement with the assessors acquitted the four
agricultural sub-overseers aforesaid of all charges, giving them the benefit of the doubt. But in disagreement with the assessors he convicted the
appellant under all the charges and sentenced him to rigorous imprisonment for four and a half years and a fine of Rs. 2,000 under section
409,Indian Penal Code, and to rigorous imprisonment for two years each under sections 120-B and477-A of the Code, the sentences of
imprisonment to run concurrently. The learned trial Judge observed in the course of his judgment as follows:- "Hence on a consideration of all
the evidence as discussed above, I find that the prosecution have fully proved their case that the accused Bimbadhar Pradhan, the D.F.P.O. has
conspired to embezzle the Government money. They have also proved that he has got an active hand and in assistance of Pitabas Sahu has
embezzled Government money amounting to Rs. 4,943-4-0 and in that act he has also actively helped Pitabas Sahu in falsifying the Government
records by making false entries

The appellant went up in appeal to the High Court of Orissa. A Division Bench of that Court allowed his appeal and set aside his convictions and
sentences under sections 409 and 477-A,Indian Penal Code, but upheld his conviction and sentence in respect of the charge of conspiracy
under section 120-B of the Code. We need not enter into the correctness of the findings of the trial court in respect of the acquittal of the other
four accused, or of the High Court with regard to the acquittal of the appellant in respect of the charges under  sections 409 and 477-A, Indian
Penal Code. The High Court held that though the appellant had withdrawn the sum of Rs. 27,000 from the Government treasury with a view to
subsidizing the procurement of oil cake, it had not been proved that there was an entrustment to the appellant. Hence the charge against him
undersection 409 failed.

As regards the charge under section 477-A, the High Court acquitted him on the ground that the documents said to have been falsified, which
were large in number, had not been mentioned in the charge and a vague statement that "accounts, cash books, stock books, petty cash sale
register, cash memos, applications from cultivators, receipts, bills, vouchers, papers, documents, letters, correspondence, etc. had been falsified"
was made. As regards the charge of conspiracy under section 120-B, the High Court observed that the most important witness to prove the
charge was the approver aforesaid (P.W. 25) who had given a full description of the conspiracy on the 23rd or 25th September 1947 between the
appellant and other sub- overseers including himself for the purpose of showing bogus purchases and bogus distribution of large quantities of oil
cake. It also observed that "Most of the witnesses examined by the prosecution to corroborate the evidence of Pitabas are themselves
accomplices in the conspiracy". The High Court found that in respect of that conspiracy the evidence given by the approver got adequate
corroboration from other independent witnesses. After setting out the evidence the High Court recorded the following finding:- "This would be
strongest corroboration of the evidence of the approver about the appellant being the prime mover and the brain behind the entire fraud. It was he
who wanted to misuse his official position and persuade his subordinates to join with him in showing false procurement and distribution figures
of oilcakes".

120-B. Punishment of criminal conspiracy -

(1) whoever is a party to a criminal conspiracy to commit an offence punishable with death, imprisonment for life or rigorous imprisonment for a
term of two years or upwards, shall, where no express provision is made in the Code for the punishment of such a conspiracy, be punished in the
same manner as if he had abetted such offence.

(2) Whoever is a party to a criminal conspiracy other than a criminal conspiracy to commit an offence punishable as aforesaid shall be punished
with imprisonment of either description for a term not exceeding six months, or with fine or with both.

Acts done by several persons in furtherance of common intention.-- When a criminal act is done by several persons in furtherance of the
common intention of all, each of such persons is liable for that act in the same manner as if it were done by him alone.

302. Punishment for murder -- Whoever commits murder shall be punished with death, or imprisonment for life, and shall also be liable to
fine.

Voluntarily causing grievous hurt by dangerous weapons or means.-- Whoever, except in the case provided for by Section 335, voluntarily
causes grievous hurt by means of any instrument for shooting, stabbing or cutting, or any instrument which, used as a weapon of offence, is
likely to cause death, or by means of fire or any heated substance, or by means of any poison or any corrosive substance, or by means of any
explosive substance, or by means of any substance which it is deleterious to the human body to inhale, to swallow, or to receive into the blood,
or by means of any animal, shall be punished with imprisonment for life, or with imprisonment of either description for a term which may extend
to ten years, and shall also be punished.

Ram Narain Popli vs Central Bureau of Investigation on 14 January, 2003

Bench: M.B. Shah, B.N. Agrawal, Arijit Pasayat

 It is the case of A-5 that except for first transaction he borrowed money from the MUL because MUL had surplus funds which MUL
were to invest and make substantial profits out of investment. A-5 returned the borrowed amount on due date with interest in each
transaction. All the said four transactions were backed by BRs as collateral security and the BRs were backed by requisite number of
units. Loan was for a short period e.g. 2nd transaction was for 12 days, 3rd was for five days, 4th was for two days and 5th for five days.
Interest rate was also high i.e. 16.75%, 21%, 26.25% and 25% respectively.

 It is his submission that it is absurd to suggest that A-5 committed any offence or offences, but the prosecution is a piece of political
revenge against A-5 for disclosing certain facts to the press against the political leaders. He contends that transactions were loan
transactions because in all these transactions the rate of interest and number; of days for which the loan was being advanced was settled
before die money and the units changed hands. This is consistent only with the transaction being a loan transaction. He also submitted
that mainly the prosecution case in the FIR dated 15.4.1993 which was lodged after preliminary enquiry which started from 15.9.1992 as
 well as in the charge-sheet submitted by the CBE on 15.12.1994 was that MUL gave loan to A-5 at a lower rate of interest and suffered
toss.

 The learned senior counsel submitted that FIR was lodged after investigation for seven months and charge-sheet was submitted after
more than one year and eight months, which itself indicates mat CBI knew that there was no case to be put up before a Court and the
investigation was kept alive for sordid and dishonest motive. He pointed out that-(I) the CBI itself understood that the FIR was based
upon the one single allegation that MUL should have received more interest than it actually received. The charge-sheet nowhere states
that at the time of the FIR the nature of these five transactions was misunderstood or that they changed their mind after investigation;
descriptions of the remaining transactions.

Conclusion:

The very heart of the crime of conspiracy is the agreement. To reach an agreement that constitutes criminal behaviour, the parties must intend to
agree and intend to achieve the same object. This article has explored the problems, both practical and theoretical, that result when applying this
seemingly simple truism of criminal law. Proving intent is not easy, particularly if: (1) the defendant denies he had the intent; (2) the defendant is
an otherwise honest business person; or (3) the courts require a different sort of intent than that required for the substantive offense. The intent
issue of conspiracy law is so very crucial that even this brief treatment of the subject may aid those who study the crime, and more importantly,
assist those who prosecute or defend persons charged with criminal conspiracy is applicable to this case as well.

BIBLIOGRAPHY:

https://indiankanoon.org/doc/591631/

https://www.indiacode.nic.in/show-data?actid=AC_CEN_5_23_00037_186045_1523266765688&orderno=127

https://devgan.in/ipc/chapter_05a.php

https://www.legalbites.in/criminal-conspiracy/