R v Calhaem

 D paid Z to murder V. When Z was in V’s home, he decided not to murder V, but suddenly went berserk and did it. D was convicted of counselling Z and CA dismissed her appeal on the grounds that “counsel” did not require a causal connection. On the basis of Widgery’s “ordinary meaning” rule, the word “counsel” implies no causal connection an simply means “authorise” or “advise” etc