Where the Crown proves a conspiracy through the direct evidence of co-conspirators rather than through hearsay declarations made in the accused's absence, a co-conspirator's rule direction is not required. A witness who assists an offender knowing of the offence but who does not receive stolen property is not an accomplice whose evidence is incapable of corroborating accomplice testimony. An Edwards v R direction is not required for evidence of attempts to bribe police investigating the offence charged where such evidence is led as circumstantial evidence of the conspiracy rather than as an implied admission based on lies.
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