The Crown is not required to prove beyond reasonable doubt the identity of the principal offender in order to convict an accessory before the fact. It is sufficient that the accessory believed a particular person was involved; the accessory need not have known the personal identity of the perpetrator, and the fact of that person's involvement need not be established. On an unreasonableness appeal from a judge alone trial, the appellate court brings its own analysis to the evidence rather than reviewing the trial judge's reasons for error.
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