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Attorney General’s Ref (No 1) [1975]

Attorney General’s Ref (No 1) [1975] QB 773 clarified the requirements for the offence of procuring, emphasising that shared intention between the person procuring an offence and the person committing it is not a necessary element.


The facts involved the defendant, X, adding alcohol to Y's drink without Y's knowledge. Subsequently, Y was convicted of drink driving. However, the judge dismissed the case against X for procuring Y's offence, asserting that there was no shared intention between X and Y.


Upon appeal, the court dismissed the appeal and affirmed that there is no requirement for a meeting of minds or shared intention between the person procuring the offence and the one committing it. Lord Widgery CJ explained that to procure means to produce by endeavour, and it does not necessitate agreement or discussion between the individuals involved. The crucial factor is establishing a causal link between the actions of the person procuring the offence and the commission of the offence itself.


Lord Widgery further illustrated the distinction by mentioning that a generous host providing alcohol to guests non-surreptitiously would not be guilty of procuring. In such a scenario, the host would be considered to have supplied the tool with which the offence is committed, as per the precedent set in R v Bainbridge [1960]. This decision clarified the nature of procuring offences, focusing on the causal link rather than shared intention.


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