The question of whether an accessory before the fact must know the manner in which the principal offence will be committed (e.g., shooting vs bashing), as distinct from merely knowing facts constituting the elements of the offence, remains unresolved. For sentencing of accessories before the fact to murder, a sentence of 15 years (NPP 11 years) was found manifestly inadequate where the offender played a critical role as getaway driver in a premeditated execution-style killing, knew of the intention to kill, showed no remorse, and had poor rehabilitation prospects; the sentence was increased to 20 years (NPP 15 years). A co-offender's sentence may be used as a comparable sentence to advance but not establish a Crown complaint of manifest inadequacy.
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