A narrative statement by a co-offender about a past event (such as an admission of forgery) cannot be admitted against an accused as having been made in furtherance of a common purpose, even where the common purpose encompassed concealment, because such a statement exposes rather than furthers the criminal enterprise. The discretion not to order a new trial may be exercised where the Crown case on admissible evidence is far short of overwhelming and the accused has served substantially all of the sentence.
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