For murder charges based on statutory complicity under ss 323(1)(a) and (c) of the Crimes Act 1958 (Vic), the prosecution need not prove that the secondary party intended the death of the victim. It is sufficient to prove that the secondary party intentionally encouraged, or agreed to, the commission of acts with intent to kill or cause really serious injury, and that those acts caused death. Section 323(1)(a) creates derivative liability (akin to aiding and abetting) while s 323(1)(c) creates primary liability (akin to joint criminal enterprise based on agency).
The full text is available to signed-in members, including the 5 later cases that cite this judgment.