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LEGALPEDIA JOURNAL VOLUME 1 ISSUE 1

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ABETMENT AND CRIMINAL CONSPIRACY: AN ANALYSIS

By Nishi Kumari*

ABSTRACT

Law and crime have a long history in the civilization of the society. Crime is basically regarded

as an act which is forbidden by the law of the land. Sometimes an offender himself is the reason

for committing an offence and sometimes it’s some hidden factor/ person who abets an offender

to commit an offence. Both Abetment and Criminal Conspiracy have its roots in Indian Penal

Code,1860. The word 'abet' has been defined as meaning to aid; to assist or to give aid; to

command, to procure, or to counsel; to countenance; to encourage; induce, or assist, to

encourage or to set another one to commit. Whereas, conspiracy is an inchoate crime and is

punishable primarily because an agreement to commit a crime is a decisive act, fraught with

potential dangers. Both the concepts are similar as both aims to commit an offence but still

there are many differences on the technical grounds. This paper aims to analysis the concept of

Abetment and Criminal Conspiracy and therefore to find out the key difference between the

both.

Keywords: Abetment, Conspiracy, Crime

* B.A.LL.B., 3rd year, Rajiv Gandhi National University of Law, Punjab.

ABETMENT AND CRIMINAL CONSPIRACY: AN ANALYSIS

Law and crime have a long history in the civilization of the society. Crime

is basically regarded as an act which is forbidden by the law of the land.

to aid; to assist or to give aid; to command, to procure, or to counsel; to

countenance; to encourage; induce, or assist, to encourage or to set an-

other one to commit. Whereas, conspiracy is an inchoate crime and is pun-

ishable primarily because an agreement to commit a crime is a decisive

act, fraught with potential dangers. Both the concepts are similar as both

-

nical grounds. This paper aims to analysis the concept of Abetment and

the both.

ABSTRACT


http://legalpediajournal.com

Nishi Kumari

B.A.LL.B., 3rd year, Rajiv Gandhi National University of Law, Punjab.

*

*

Keywords : Abetment, Conspiracy, Crime

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1. INTRODUCTION

The very definition and concept of crime varies not only according to the values of a particular

group and society, its deals, faith, religious attitudes, customs, traditions, and taboos, but also

according to the form of government, political, economic structure of the society and number

of other factors. For instance, what is an offence against property in a capitalist society may be

a lawful way of living in a socialist society.

People may believe that if they plan to commit a crime, but do not actually go through with it,

that they will not be held responsible for a crime. This belief is mistaken; however, as there are

laws set out for specific offences called “inchoate” offences. Inchoate means that a criminal

act was anticipated or prepared for, but not completed. The major offences which are included

in this are: Abetment and Conspiracy.

Indian Penal Code is a piece of comprehensive legislation. The code embodies the general

penal law of country and is the sole authority in respect to the general conditions of work, the

definitions of the specific offences in Code, and the conditions of exemptions from criminal

liability. Some crimes are cognizable, and some are not.2

Traditional and conventional crimes are rooted in time and customs and Indian Penal Code

represents its core. The Code punishes such acts against persons and their property as are

universally accepted as injurious to all civilized societies and acts which offend against

fundamental principles on which the existence of human being as society rests. These

fundamentals are more or less of a permanent nature and will endure for a long time to come.

The term 'abetment' in criminal law indicates that there is a distinction between the person

abetting the commission of an offence (or abettor) and the actual perpetrator of the offence or

the principal offence or the principal offender. Whosoever, either prior to or at the time of the

commission of an act, does anything in order to facilitate the commission of that act, and

thereby facilitate the commission thereof, is said to aid the doing of that act.3

Russell remarks the crime of conspiracy as, “affords support for any who advance the

proposition that criminal law is an instrument of government.”4 The IPC was amended in 1870

as to insert S. 120-A IPC. Chapter V-A has been introduced in the code by the Criminal Law

2 Cr.P.C., (1973), sec. 2 (c) 3 Indian Penal Code, sec. 107 4 Russell on Crimes, vol. 1 (11th Ed.) p. 213

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Amendment Act (8 of 1913). The object of the amendment was to prevent the commission of

crime by nipping them in the bud.5 As stated above the inclusion of Chapter V-A in the Penal

Code was designed to assimilate the provisions of English law. This chapter was inserted in

the Indian Penal Code in 1913. Conspiracy, at common law, had its origin primarily as a civil

wrong, but was lately made punishable as criminal wrong.6

2. ABETMENT

In Indian Penal Code, Abetment is defined under section 107 as:7

Abetment of a thing - A person abets the doing of a thing, who: -

a. Instigates any person to do that thing; or

b. Engages with one or more other person or persons in any conspiracy for the doing of

that thing, if an act or illegal omission takes place in pursuance of that conspiracy, and

in order to the doing of that thing; or

c. Intentionally aids, by any act or illegal omission, the doing of that thing.

In comprehensive way under Indian Penal Code, abetment can be defined as, a person becomes

liable as an abettor if he instigates another to commit a crime or engages in a conspiracy with

another to commit a crime and some act is done in furtherance of such conspiracy or if he

intentionally aids another in order to facilitate the commission of a crime. The term 'abet' in

general usage means to assist, advance, aid, conduce, help and promote. The word 'abet' has

been defined as meaning to aid; to assist or to give aid; to command, to procure, or to counsel;

to countenance; to encourage; induce, or assist, to encourage or to set another one to commit.8

The term 'abetment' in criminal law indicates that there is a distinction between the person

abetting the commission of an offence (or abettor) and the actual perpetrator of the offence or

the principal offence or the principal offender.

Abettor is a person who abets an offence, who abets either the commission of an offence, or

the commission of an act which would be an offence, if committed by a person capable by law

5 State of A.P. v. Cheemalapati Caneswara Rao, AIR1963 SC 1850; (1963) 1 Cri L J 67 6 Gour, Hari Singh, Penal Law of India, 11th Edn., Vol. II, 2000, pp. 1101-1135 7 Indian Penal Code, 1860, sec.107 8 Kartar Singh v. State of Punjab, 1994 Cri LJ 3139; See also Sanju v. State of Madhya Pradesh, (2002) 5 S.C.C. 371(India)

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of committing an offence with the same intention or knowledge as that of the abettor. The

essentials are:

(1) There must be an abettor;

(2) He must abet, and

(3) The abetment must be an offence or an act which would be an offence, if committed

by a person capable in law of committing the offence with the same intention or

knowledge as that of the abettor.9

The chapter on abetment contains 15 sections.

� Section 107 which defines abetment generally speaks of three kinds of abetment, viz.,

abetment by instigation, abetment by conspiracy and abetment by aid.

� Section 108 explains as to when an abetment of an offence takes place, and S. 108-A

provides for the case of abetments-in India of an offence committed in a foreign

country.

� Section 109 prescribes the punishment for the offence of abetment when the offence

abetted is committed, while

� S. 110 prescribe the punishment for abetment where the person abetted commits the act

with a different intention or knowledge from that of the abettor.

� Section 111 provides for cases of abetment resulting in a different offence but which is

a probable consequence thereof.

� Section 112 provides for cumulative punishment in cases covered by S. 111.

� Section 113 which is supplementary to S.111 provides for punishment in cases where

the act abetted causes a different effect from that intended by the abettor.

� Section 114 provides for cases where the abettor is present at the time of the offence

and makes him liable for the main offence and not merely as an abettor.

� Sections 115 and 116 prescribe for the punishment in cases where the offence abetted

is not committed.

� Section 117 deals with abetment of offences by the public generally or large groups of

persons.

9 Emperor v. Parimal Chatterjee, A.I.R. 1932 Cal 760 (761); (1939) 34 Cr LJ 78 (India). See Nelson’s Indian Penal Code, 7th Edn., (1981), Vol. I, p. 275

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� Section 118 prescribes the penalty for concealing the existence of a design in another

to commit a grave offence.

� Sections 119 and 120 provide for punishment in the case of public servants and others

respectively for concealment of a design in another person to commit the offence not

covered by S. 118.

2.1 ABETMENT BY INSTIGATION

The word 'instigate' literally means to goad, urge forward, provoke, incite, or encourage to do

an act and a person is said to instigate another when he actively suggests or stimulates him to

the act by any means, or language, direct or indirect, whether it take the form of express

solicitation or of hints, insinuation or encouragement or a wilful misrepresentation or wilful

concealment of a material fact.

It is not necessary that express words should be used to indicate what should be done by the

person to whom the directions are given. While there has to be a reasonable certainty in regard

to the meaning of the words used in order to decide whether there was incitement, it is not

necessary in law to prove the actual words used.

Advice amounts to instigation only when intended to actively suggest or stimulate the

commission of an offence. Mere acquiescence does not amount to instigation. Thus the word

denotes incitement or urging to do some drastic or unadvisable action or to stimulate or incite.

Presence of mens rea, therefore, is the necessary concomitant of instigation. It is common

knowledge that the words uttered in a quarrel or in a spur of the moment cannot be taken to be

uttered with mens rea required to constitute instigation as they are uttered in a fit of anger and

emotional state.10

Instigation as a form of abetment has generally been one of the essential considerations in cases

involving death of young brides or women within seven years after marriage, as a consequence

of dowry harassment. The apex court has laid down that before anybody can be punished for

abetment of suicide, it must be proved that the death in question was a suicidal death.11

10 See Swamy Prahaladdas v. State of M.P. & Am., 1995 Supp. (3) SCC 438 (India); Mahendra Singh v. State of M.P., 1995 Supp. (3) S.C.C. 731 (India); Ramesh Kumar v. State of Chhattisgarh, (2001) 9 S.C.C. 618 : 2001(4) RCR (Cri.) 537 (S.C.) (India) ; Seeta Hemchandra Shashittal v. State of Maharashtra, (2001) 4 S.C.C. 52 (India) 11 Wazir Chand v. State of Haryana, A.I.R. 1989 S.C. 378; Ramesh Chandra Mondal v. State, 1991 Cr LJ 2520 Cal (India)

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In Jamuna Singh v. State of Bihar12, the offence of abetment is complete when the alleged

abettor has instigated another or engaged with another in a conspiracy to commit the offence.

It is not necessary for the offence of abetment that the act abetted must be committed.

It is only in the case of the person abetting an offence by intentionally aiding another to commit

that offence that the charge of abetment against him would be expected to fail when the person

alleged to have committed the offence is acquitted of that offence.13

2.2 ABETMENT BY CONSPIRACY

A person is said to abet the commission of an offence by conspiracy, if he enters into an

agreement with one or more persons to do a legal act by illegal means, or to do an illegal act,

and some act is done in pursuance thereof. A conspiracy to do a thing is a combination of two

or more persons with a common design of doing a specific thing. It has been held that where a

criminal conspiracy amounts to an abetment under S. 107, it is unnecessary to invoke the

provisions of Ss. 120-A and 120-B, as the Code has made a specific provision for the

punishment of such a conspiracy.

2.3 ABETMENT BY AID

A person is said to abet the commission of an offence if he intentionally renders assistance or

gives aid by doing an act or omitting to do an act. Mere intention to render assistance is not

sufficient. There must be some active conduct on the part of the abettor and the act must be

accomplished in pursuance thereof.

Aid may be given both by an act of commission as well as by an act of illegal omission. For

instance, if a police officer knowing that certain persons were likely to be tortured for the

purposes of extorting confession keeps himself away from the place, he is liable for abetment

to the offence of extortion by an act of omission.14

a) The act or omission which constitutes the aid must have been done intentionally;

12 Jamuna Singh v. State of Bihar, A.I.R. 1967 S.C. 553 at 554 : 1967 Cri. LJ 541 (India) 13 Ibid 14 Faguna Kama Nath v. State of Assam, A.I.R. 1959 S.C. 673 (India)

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b) The aid must have been given either prior to or at the time of the commission of the

offence abetted.

3. CRIMINAL CONSPIRACY

In English law, "if two or more persons agree together to do something contrary to law, or

wrongful and harmful towards another person, or to use unlawful means in the carrying out of

an object not otherwise unlawful, the persons who so agree commit the crime of conspiracy."15

No overt act in pursuance of the conspiracy is necessary, the illegal combination itself being

the gist of the offence. The overt acts which may follow the conspiracy form, of themselves,

no part of the conspiracy.

In Mulcahy v. R.16 the House of Lords stated, "A conspiracy consists not merely in the intention

of two or more but in the agreement of two or more to do an unlawful act by unlawful means.

So long as such a design rests in intention only it is only indictable. When two agree to carry it

into effect, the very plot is an act in itself and the act of each of the parties promise against

promise actus contra actum capable of being enforced if lawful, punishable if for a criminal

object or for the use of criminal means." After the judgment of the House of Lords in the case

of Mulcahy v. R.17 IPC was amended in 1870 as to insert S. 120-A IPC. Chapter V-A has been

introduced in the code by the Criminal Law Amendment Act (8 of 1913). The object of the

amendment was to prevent the commission of crime by nipping them in the bud.18

120A. Definition of criminal conspiracy - When two or more per-sons agree to do, or

cause to be done: -

(1) an illegal act, or

(2) an act which is not illegal by illegal means, such an agreement is designated

a criminal conspiracy: Provided that no agreement except an agreement to

commit an offence shall amount to a criminal conspiracy unless some act

besides the agreement is done by one or more parties to such agreement in

pursuance thereof.

15 Halsbury's Laws of England, (3rd Ed.) vol. 10. p. 310-1 16 Muchay v. R (1868) LR 3 HL 30 (England) 17 Ibid 18 State of A.P. v. Cheemalapati Caneswara Rao, A.I.R. 1963 S.C. 1850; (1963) 1 Cri L J (India)

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So far as the law of present day is concerned the House of Lords has declared:

(a) that the gist of conspiracy is the agreement, whether or not the object is attained

(b) that the purpose of making such agreements punishable is to prevent the commission

of the substantive offence before it has even reached the stage of attempt and

(c) that it is all part and parcel of the preservation of the Queen's peace within the

realm.19

Conspiracy under the Indian Penal Code originally was punishable only in two forms, viz., (i)

conspiracy by way of abetment and (ii) conspiracy involved in certain offence. In the former

an act or illegal omission must take place in pursuance of conspiracy in order to punishable

while in the latter membership suffices to establish the charge of conspiracy.

Thus the Indian Penal Code deals with the law relating to criminal conspiracy:

� as a substantive offence;20

� as a form of abetment (Chapter V, section 107);21

� to wage, attempt or abet waging of war against the Government of India. (Chapter VI,

section 121A);22

� involvement in certain offences, such as assembling for purpose of committing dacoity.

Before passing of the Criminal Law Amendment Act of 1913, a conspiracy to do an illegal act

was punishable only when such act amounted to an offence. It was also essential in the words

of section 107(2) of the Code that an act or illegal omission should have taken place in

pursuance of the conspiracy and in order to the doing of the act which was the object of the

Conspiracy.

The Criminal Law Amendment Act, 1913 has, however, introduced two rather drastic changes

in the respect. By section 120B punishment is provided for criminal conspiracies of all kinds

viz.,

� whether, according to the requirement of section 107, an overt act has or has not taken

place in pursuance of such conspiracy, and;

19 Kenny, Outlines of Criminal Law (Ed. Turner 17th Ed.) p. 89; See also Board of Trade v. Owen (1957) 2 WLR 351 at 357 20 Chapter VA, secs. 120A and 120B, I.P.C. added to the Indian Penal Code by Act VIII of 1913 21 Chapter V, sec. 107(2), I.P.C. 22 Added to the I.P.C. by Act XXVII of 1870, sec.4

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� whether, as required by sections 109, 115 or 116, the object of conspiracy is or is not

the commission of an offence.

In Mohd. Khalid v. State of West Bengal23 and Davender Pal Singh v. State of NCT of Delhi24

, the Supreme Court after referring to the American and the English legal position on the law

of conspiracy summarized the broad essential elements of conspiracy thus:

� an object to be accompanied;

� a plan or scheme embodying means to accomplish that object;

� an agreement or understanding between two or more accused persons whereby, they

become definitely committed to corporate for the accomplishment of the object by the

means embodied in the agreement, or by any effectual means; and

� in the jurisdiction where the statute requires, an overt act.

The court further held that the Indian law broadly conforms to the English legal position on the

law of criminal conspiracy. Thus, the provisions of Ss. 120 A & 120B IPC have brought the

law of conspiracy in India in tune with the English law by making the overt act unessential

when the conspiracy is to commit any punishable offence. The provisions, in such a situation

do not require that each and every person who is party to the conspiracy must do some overt

act towards the fulfilment of the object of conspiracy the essential ingredients being an

agreement between the conspirators to commit the crime and if these essentials and

requirements are established, the act would fall within the trapping of the provisions contained

in S. 120B.

4. CASE ANALYSIS

1. The use of the word "illegal" in the definition of criminal conspiracy in S.120-A

IPC is extremely comprehensive and would make even a case of civil trespass

23 Mohd. Khalid v. State of West Bengal (2002) 7 S.C.C. 334 (India) 24 Davendera Pal Singh v. NCT of Delhi (2002) 5 S.C.C. 234 (India)

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indictable, as a criminal conspiracy. In State of Maharashtra v. Somnath Thapa25

Supreme Court explained the ingredients of conspiracy and observed:

―To establish a charge of conspiracy, knowledge about indulgence in either

an illegal act or a legal act by illegal means is necessary. In some cases, intent

of unlawful use being made of the goods or services in question may be inferred

from the knowledge itself... Finally when the ultimate offence consists of a chain

of actions, it would not be necessary for the prosecution to establish, to bring

home the charge of conspiracy, that each of the conspirators had to know of

what the collaborator would do, so long as it is known that the collaborator

would put the goods or services to an unlawful use.

Thus, even knowledge of an illegal act is enough to hold one guilty of conspiracy.

But as per the Ss. 120A and 120B it is the intent by two or more which is necessary

to constitute conspiracy. The law relating to conspiracy aims at punishing guilty

intentions because no overt act is required for the same. However, it can be inferred

that mem rea is not a necessary ingredient of the charge of conspiracy to commit an

offence.

2. The Supreme Court in State v. Nalini (Rajiv Gandhi Assasination case)26, dealt at

length the law of conspiracy, reviewed case law and culled out several principles

governing conspiracy. On the night of 21-5-1991 Rajiv Gandhi, the former Prime

Minister of India was assassinated by a human bomb. This incident was a result of

conspiracy. Wadhwa, J laid down following broad principles governing the law of

conspiracy:

i. Under S. 120 -A IPC offence of criminal conspiracy is committed when two

or more persons agree to do or cause to be done an illegal act or legal act by

„illegal‟ means.

ii. Acts subsequent to the achieving of the object of conspiracy may tend to

prove that a particular accused was party to the conspiracy

25 State of Maharashtra v. Somnath Thapa 1996 Cri LJ 2448 : A.I.R. 1996 S.C. 1744 (India) 26 State (C.B.I/S.I.T) v. Nalini (1999)5 S.C.C. 253 (India)

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iii. Conspiracy is hatched in private or in secrecy. It is rarely possible to establish

a conspiracy by direct evidence.

iv. Conspirators may, for example be enrolled in a chain - A enrolling B, B

enrolling C, and so on; and all will be members of a single conspiracy if they

so intend and agree, even though each member knows only the person who

enrolled him and the person whom he enrols.

v. When two or more persons agree to commit a crime of conspiracy, then

regardless of making or considering any plans for its commission, and despite

the fact that no step is taken by any such person to carry out their common

purpose, a crime is committed by each and every one who joins in the

agreement

vi. It is not necessary that all conspirators should agree to the common purpose

at the same time.

vii. A charge of conspiracy may prejudice the accused because it forces them into

a joint trial and the court may consider the entire mass of evidence against

every accused.

viii. It is the unlawful agreement and not its-accomplishment, which is the gist or

essence of the crime of conspiracy

ix. It has been said that a criminal conspiracy is a partnership in crime, and there

is in each conspiracy a joint or mutual agency for the prosecution of a

common plan.

x. A man may join a conspiracy by word or by deed.

The essence of criminal conspiracy embodied in S. 120A is the unlawful combination and

ordinarily the offence is complete when the combination is framed.

5. DIFFERENCE BETWEEN ABETMENT AND CRIMINAL

CONSPIRACY

o Abetment is a process by which one or more engage or employ other(s) for commission

of an offence. The former i.e., the person, who abets is called the „abettor‟, while the

latter i.e., the person who commits the offence with his own hands is called the

„principal offender‟.

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o But, conspiracy is a process by which an agreement is entered into between two or more

persons for commission of an illegal act or doing/committing a lawful/ legal act by

illegal means. The parties to the agreement are called „Conspirators‟

o In the offence of abetment, a mere combination of persons or agreement between them

is not enough but an act or illegal omission must take place in pursuance of the

conspiracy and in order to the doing of the thing conspired for,

o But in conspiracy, the mere agreement is enough, if the agreement is to commit an

offence.

o Abetment can be committed by one or more, whereas conspiracy can be committed by

two or more.

o In abetment, sanction of competent authorities is not necessary to proceed against the

abettors, who merely abetted to commit a crime.

o While in conspiracy, sanction of competent authorities is necessary to proceed against

the conspirators who merely agreed to commit a crime.

o Abetment is genus while the conspiracy is species.

o Abetment per se is not a substantive offence whereas criminal conspiracy is a

substantive

o offence by itself and is punishable.

o Abetment may be committed in various methods/ways viz., instigation, conspiracy,

intentional aid etc., but conspiracy is one of the methods of abetment.

o Crime of Abetment is explained in Sections 107 to 120 of the code while Crime of

Conspiracy is explained in Sections 120- A & 120-B of the Code.

o Section 109 of the code is concerned only with the punishment of abetments for which

no express provision is made under the Penal Code. A charge under Section 109 should,

therefore, be alone with some other substantive offence committed in consequence of

abetment.

However, the offence of criminal conspiracy is, on the other hand, an independent offence. It

is made punishable under Section 120 В of the code for which a charge under Section 109 of

the Code is unnecessary and, indeed, inappropriate.

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6. CONCLUSION

Under the Penal Code a person becomes liable as an abettor if he instigates another to commit

a crime, or engages in a conspiracy with another to commit a crime and some act is done in

furtherance of such conspiracy or if he intentionally aids another in order to facilitate the

commission of a crime. The term 'abet' in general usage means to assist, advance, aid, conduce,

help and promote. The word 'abet' has been defined as meaning to aid; to assist or to give aid;

to command, to procure, or to counsel; to countenance; to encourage; induce, or assist, to

encourage or to set another one to commit.

Thus, conspiracy is an inchoate crime and is punishable primarily because an agreement to

commit a crime is a decisive act, fraught with potential dangers; but to bring an agreement to

commit a civil wrong within the range of criminal conspiracy is to stretch the rationale of law

to the farthest limit. In its broad reach it can be made to do great evil.

The United States of America, France, United Kingdom and Canada are the some of the

countries whose Penal Laws are more strengthened by keeping the social change in view for

effective control of Law and Order. Every citizen should, with a reasonable degree of certainty

must know the potential penal consequence of any act he/she commits. Law and order can be

maintained through sociological jurisprudence that is social engineering, as opined by Rosco

Pound. The objective and philosophy of the penal law is the same as that of sociological

jurisprudence. This is unfortunate, for the absence of a distinct sentencing phase and the

attention to sentencing process which enables and impedes the growth of a mature

jurisprudence. By maintaining law and order social welfare can be attained in any society very

easily.

7. SUGGESTIONS

Crime rate in India has been considerably increasing from year to year and the convictions rate

hard become very low and that too the courts have been awarding very merge punishments by

using them vide discretionary powers.

There are more chances to get lenient punishment by the proved offenders due to lose frame

work of the legislature in fixing the punishment for several offences in the Code.

There is more probability to apply the personally favored brain and individual opinion of the

judicial officers while conforming the sentence to the offenders, due to wide discretion

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available in the present sentencing jurisprudence. So that, there are more chances to escape for

the accused from the clutches of the law.

Already Indian Criminal Justice System is working on the motto of “hundred criminals can be

escaped, but one innocent should not be punished”.

In these circumstances, if the minimum punishment is conformed in the penal statutes in

general and in Indian Penal Code in particular as it is covering substantial portion of the

offences in India by the legislature through amendments, the trial court judge will be curtailed

by the Statute and he is forced to give punishment within the limit stipulated by the legislature.

Crime is age-old phenomenon, a deep-rooted evil, born and developed along with the

development of man and gradually became universal malady afflicting each and every society.

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