Essentially, if the prosecution can establish that an agreement has been reached or formed between the parties to commit a criminal offence and the parties then proceed to participate in that offence, then each of the participants are equally guilty for that offence regardless of their individual roles. The agreement to commit and participate in an offence obviously need not be express and can arise at the time the offence is being committed.

Under the principle of extended joint criminal enterprise or “common purpose” a participant is also liable for any offence other than the agreed offence provided, the further offence falls within the scope of the common purpose – the test is a subjective test hence, the prosecution must prove that the accused was aware of the possibility of the other offence being committed.