A joint enterprise to possess prohibited imports does not cease when physical possession passes from one participant to another; the enterprise continues among all participants. Telephone conversations between co-conspirators inquiring about the progress of the enterprise are made 'in furtherance' of the common purpose and are admissible against other participants under the Tripodi/Ahern rule and s 87(1)(c) of the Evidence Act 1995. Evidence of large sums of cash found concealed on an accused at the time of arrest is circumstantial evidence of the offence, not tendency evidence requiring a warning.
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