Under s 10(1) of the Criminal Code (WA), a person cannot be convicted as an accessory after the fact to murder in respect of acts of assistance performed before the victim has died. The offence of murder is not complete until the victim's death, and the accessory must have known that the offence had been committed at the time the assistance was given. However, accessory liability for lesser offences (such as intentionally causing grievous bodily harm) may arise before the victim's death.
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