R v Kenning and others [2008] All ER (D) 317 (Jun)
There can be no conviction for aiding, abetting, counselling or procuring an offence unless the actus reus of the substantive offence is shown to have occurred. Moreover, it is not an offence to attempt to aid, abet, counsel of procure the commission of an offence. An agreement to aid and abet an offence is not capable of constituting a criminal conspiracy.
