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R v Becerra and Cooper 1976

R v Becerra and Cooper [1976] 62 App R 212 addressed the criteria for successfully withdrawing from a criminal enterprise, emphasising the necessity of unequivocal communication of withdrawal to other perpetrators.

Becerra providing Cooper with a knife before a burglary. Becerra decided to leave the scene when he observed someone approaching, and he shouted "come on, let’s go" to Cooper. Subsequently, Cooper used the knife to kill the victim, leading to Becerra being convicted as an accessory to the murder.

The Court of Appeal dismissed the appeal, asserting that the words "come on, let’s go" were insufficient as a communication of withdrawal. Roskill LJ highlighted that withdrawing from a common enterprise required more than a mere change of intention and physical departure. The crucial element was the timely communication of the intention to abandon the common purpose to those who intended to continue.

In essence, the judgment clarified that successful withdrawal entails a practical and reasonable communication of the intention to abandon the joint enterprise, specifically directed at those who wish to persist in the criminal activity. The standard for withdrawal remains context-dependent, with timely and explicit communication being a key element in the process.

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