Where the Crown's alternative case in murder is based on aiding and abetting, the trial judge must direct the jury on manslaughter by aiding and abetting as an alternative, not merely on manslaughter by concert. The third head of the conventional aiding and abetting direction from R v Lowery & King (No. 2) — intentionally conveying assent and concurrence — requires more than mere passive acquiescence; it connotes a degree of passive participation suggesting willingness to assist.
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