The law as to who can be prosecuted for *acts of another*, or for the *acts of a group*, is described by: accessory, aid and abet, counsel and procure, acting in concert, common purpose, extended common purpose and joint criminal enterprise. - **Aid:** The ordinary meaning of aid is to give help support or assistance to. - **Abet:** A common dictionary meaning of abetting is encouraging or countenancing, and this is to be remembered when the words aiding or abetting alone are used. To incite, instigate or encourage. - **Counsel:** To advise, urge the doing or adoption of something; or to recommend a plan. - **Procure:** To procure means to produce by endeavour a thing by setting out to see that it happens and taking the appropriate steps to produce that happening. - *Presence* does not necessarily mean immediate physical presence (Likiardopoulos [2010] VSCA 344) - But presence alone is insufficient to prove complicity. - R v Clarkson [1971] 1 WLR 1402; It is not enough then that the presence of the accused person has in fact, given encouragement. It must be proved that he intended to give encouragement; that he wilfully encouraged. - R v Johnson [2007] QCA 76: That passage emphasise three things: - That proof of mere presence at the scene of the offence will not suffice; and - That the prosecution must establish that the intention behind the presence is to encourage; and - That the prosecution must establish that the effect of the presence is to encourage.