Past conduct (an assault) can constitute a 'threat to cause future detriment' within the meaning of s 415(1)(b) of the Criminal Code where the circumstances imply a continuing threat. The sentencing range for torture involving cold-blooded detention and torture for money by strangers using firearms is 10 to 12 years imprisonment, following R v Cowie. An accomplice direction need not use the precise words of the Benchbook provided the substance of the warning is conveyed.
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