An individual who personally submits false documents to a third party on behalf of a company 'uses' those documents for the purposes of s 347 of the Criminal Code 2002 (ACT), and the fact that the intended gain is for the company does not preclude conviction. The common sense test of causation applies to obtaining property by deception under s 326, and the causal link is not broken by the fact that the property was also earned through performance of contractual work.
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