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R v O'Brien (2007), 250 NSR (2d) 193


O convicted of counseling R to rob a store. R bought drugs from O. O told R that it would be easy to rob since there was only a 16 yr old girl working. Also agreed that R should paint her face


For a conviction of counseling others to commit offences – it may be sufficient if a conversation before the offence was supportive of X committing the offence, thus actively inducing the commission of the offence.


Before the discussion with O, R had not made up her mind to rob the store.
Crown does not have to prove motive – but if evidence then it can be relevant to proving intent

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