The offence of robbery in company under s 97(1) of the Crimes Act 1900 (NSW) is satisfied in two alternative ways: (1) presence at the scene with intention to physically participate if required, even if the victim is unaware of the offender's presence; or (2) making one's presence known to the victim so that the victim is confronted by the combined force of two or more persons, even if the offender did not intend to physically participate. R v Galey [1985] 1 NZLR 230 is confined to its facts where the victim was unaware of the second person's presence.
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