The expression 'prosecute an unlawful purpose' in s 302(1)(b) of the Criminal Code is not limited to the strict elements of the offence but extends to acts done in the course of escaping the scene. For s 8 liability for manslaughter arising from a s 302(1)(b) murder, it is sufficient to prove the secondary offender knew of the common plan and that violence likely to cause death was a probable consequence; it is not necessary to prove the secondary offender knew the principal intended to kill or do grievous bodily harm. The words 'counselled' and 'procured' in s 7(1)(d) are ordinary English words requiring no further judicial explanation where their meaning is clear. The question of the precise requirements for s 8 liability for murder (as distinct from manslaughter) under s 302(1)(b) was left open.
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