Inchoate offences Essay

Custom Student Mr. Teacher ENG 1001-04 8 August 2016

Inchoate offences

The word inchoate offence in ordinary sense means just begun or undeveloped. An inchoate can be defined as a preparation for committing a crime. The Inchoate offences can also be termed as preliminary crimes or anticipatory crimes. Inchoate offence “has been defined as conduct deemed criminal without actual harm being done provided that the harm that would have occurred is one the law tries to prevent”.. For an inchoate offence there must be Mens Rea and in some cases there must be Actus Reus also. If A after procuring a loaded gun fires at B but however B escapes, but even though A will be liable for punishment for attempting the offense. And also in above case there exists _Mens Rea_ and _Actus Reus_ but however it does not made any injury. This illustration can be categorized into an inchoate offence.

Criminal liability is not limited to those people who succeed in committing it also exceeds to those who try to commit and offence whether they succeed or fails are not in question of matter. ‘The Indian Penal Code 1860 has accordingly made provision for the punishment of persons involved in such preparatory acts in order to prevent the crimes from being committed’.[1: Gaines, L. K., Kaune, M., & Miller, R. L. (2001). Criminal justice in action: The core. Australia: Wadsworth Pub.][2: Guar, K. D. (2008). Preliminary crimes. In criminal law: cases and materials (5th ed., p. 245). New Delhi, India: LexisNexis Butterworth’s.]

_’Actus Non Facit Reum Nisi Mens Sit Rea_ insists that no criminal liability can generally be fastened to an individual for merely either having guilty mind or an evil design (_mens rea_) or committing a blame worthy prohibited act (_actus reus_ ) unaccompanied with the required culpable state of mind or requisite foresight of its evil consequences’.[3: Atchuthen, P. P., Suresh, V., & Nagasaila, D. (2012). Attempt. In PSA Pillai’s Criminal law (11th ed., p. 179). New Delhi, India: LexisNexis Butterworths.]

According to English law the crime which penalise conduct before the commission of the crime are known as inchoate offences. Common law has developed the three types of inchoate offences such as attempt, conspiracy and incitement. It classify attempts as (where the defendant has taken steps “towards carrying out a complete crime”, incitement, where the defendant has encouraged others to commit a crime, and conspiracy, where the defendant has agreed with others to commit a crime. In each case, the defendant “has not himself performed the actus reus but is sufficiently close to doing so or persuading others to do so, for the law to find it appropriate to punish him”).[4: Inchoate offences in English law – Wikipedia, the free encyclopaedia. . Retrieved March 29, 2014, from]



‘Attempt in criminal law is an offense that occurs when a person comes dangerously close to carrying out a criminal act, and intends to commit the act, but does not in fact commit it’.’In English law, an attempt is defined as ‘doing an act which is more than merely preparatory to the commission of the offence’ according to the Criminal Attempts Act 1981′.Mainly there are three types of criminal attempt. The first one is a complete attempt that when a person takes every action required to commit a crime but fails to succeed it that is for example A after procuring a loaded gun fires at B but however B escapes , this is a complete attempt. Second one is an incomplete attempt.

This is when a person abandons or is prevented from completing a crime due to an event beyond his control such as due to the arrival of police on the spot etc. can be categorised in this type. Next one is an impossible attempt. It arises when the convict makes a mistake in committing a crime for example firing the gun only to realize that it was not loaded.[5: Attempt – Wikipedia, the free encyclopaedia. . Retrieved March 30, 2014, from][6: Herring, Jonathan (2013). Criminal Law Statutes 2011-2012. Hoboken: Taylor and Francis.]

‘It can be drawn that criminal offenses by a person have four distinct stages.

The formation of the intention to commit it;

The preparations for commission of the contemplated crimes;

The attempt to commit it ;

If the third stage is successful, the commission of the intended crime.'[7: Atchuthen, P. P., Suresh, V., & Nagasaila, D. (2012). Attempt. In PSA Pillai’s Criminal law (11th ed., p. 177). New Delhi, India: LexisNexis Butterworths.]

Among these, criminal law does not penalise the first two stages because it is not possible to look so deep into the mind of a person to prove his inner intention. In early times criminal attempt was not punished under common law or by Indian Penal Code 1960. This is because, ‘if the intention and the preparation were made punishable it would be impossible to prove that the object of n accused was to commit an offense’.[8: Guar, K. D. (2008). preliminary crimes. In Criminal Law: Cases and Materials (5th ed., p. 263). New Delhi, India: LexisNexis Butterworths.]

‘Early common law did not punish attempts; the law of attempt was not recognised by common law until the case of _Rex v. Scofield_ in 1784’.[9: Lippmann M. (2010). Contemporary Criminal Law, 2nd Ed and Texas State Supplement for Lippmann’s Contemporary Criminal Law, 2nd Ed. Sage Pubns.]

Mainly there exists three elements for a criminal attempt they are firstly an intention to commit a crime, secondly an act towards the commission of the crime and thirdly a failure to commit crime.


Attempt to commit offences in general under s 511 of the IPC 1860;

_Abhayanand Mishra v State of Bihar_ [10: AIR 1961 SC 1698]

_Malkiat Singh v State of Punjab_[11: AIR 1970 SC 713]

Attempt to commit capital offences , like murder , culpable homicide and robbery ;[12: Indian Penal Code 1860,ss 307, 308 and 309]

_Om Prakash v State of Punjab_[13: AIR 1961 SC 1782]

_Emperor v Vasudeo Balvant Gogte_[14: AIR1932 Bom 279]

Attempt to commit suicide;[15: Indian Penal Code 1860, s 309]

Attempt to commit crime against state, head of state, sediction etc.; [16: Indian Penal Code 1860,ss 121, 124, 124A ,125, 130 ,131, 152, 153A, 161 ,162 ,163 ,165 ,196, 198, 200, 213 ,239 ,240, 241 ,251 ,385 ,387 ,389, 391 ,397 ,398 and 460]


“_Mens Rea_ in inchoate offense is not merely a condition of fault. It is a component of the danger of criminal harm that determines the need for forceful intervention”. A criminal intention includes a dual intention , those are an individual must intentionally do an act that are proximate to completion of a crime and the other one is that an individual must possess the specific intent or purpose to achieve criminal objective.[17: Enker, A. N. (1977). Mens Rea and Criminal Attempt. Law and Social Inquiry-journal of The American Bar Foundation, 2(4), 845. doi:10.1111/j.1747-4469.1977.tb00733.x]


In criminal attempt, the objective approach requires an act that comes extremely close to the commission of the crime. It also distinguishes preparation or the planning and purchasing of the materials to commit a crime. And the objective approach stresses the danger posed by a defendant’s acts; the subjective approach focuses on the danger to society presented by a defendant who possesses a criminal intent. There also exists subjective approach to attempt focuses on an individual’s intent rather than on his or her acts.


It is simple to say that an attempt to commit offence begins where preparation to commit it ends, but it is difficult to find out where one ends and the other begins. To solve this riddle various tests have been laid down by the courts. These are as follows:

1) The Proximity Test: – Proximity cause as explains is the causal factor which is closes, not necessarily in time or space, but in efficacy to some harmful consequences; in other words, it must be sufficiently near the accomplishment of the substantive offence.

In Sudhir kumar Mukherjee v state of west Bengal and Abhayanand Mishra v The State Of Bihar, the Supreme Court explained the offence of attempt with help of the proximity test, saying that:-[18: AIR 1973 SC 2655][19: AIR 1961 SC 1698]

“A person commits the offence of ‘attempt to commit a particular offence’ when-

a) He intends to commit that particular offence; and

b) He having made preparation with the intention to commit the offence, does an act towards its commission; such an act need not to be the penultimate act towards the commission of that offence but must be an act during the course of committing that offence.

2) The Locus Poenitentiae test:- The Latin expression speaks about time for repentance. In Locus Poenitentiae the word Locus means, a place,- a word frequently used to denote the place in or at which some material act or even such as crime, delict or breach of contract took place. Locus Poenitentiae means the opportunity to withdraw from a bargain before it has become fully Constituted and become binding. In simple language an act will amount to a mere preparation if a man on his own accord, before the criminal act is carried out, gives it up. It is, thus, possible that he might of its own accord, or because of the fear of unpleasant consequences that might follow, desists from the completed attempt. If this happens, he does not go beyond the limits of preparation and does not enter the arena of attempt. He is, thus at the stage of preparation which cannot be punished.

3) Impossibility Test

‘An act which is impossible to commit cannot be attempted and so it is not culpable’. In ‘Asagarali Pradhaniu v. Emperor’, what the appellant did was not an “act done towards the commission of offence”, and therefore, he could not be convicted. But in a Malaysian case the accused was held liable for an attempt to cause abortion when the woman was not pregnant. Even the appeal court held the accused liable because the circumstances in this case seemed to be exactly covered by the illustration to section 511 IPC. The act itself is impossible of performance and yet it constitutes an offence of attempt to commit crime. This was precisely the position in English Law before Houghton v. Smith case.[20: Gaur, K. D. (1998). Indian Penal Code (2nd ed., pp. 696-707). Oxford IBH.][21: (1934) ILR 61, 64]

In ‘_R v. Shivpuri’_ it has been held that, if the mental element has proceeded to commit the act but failed his responsibility for attempt would be evaluated in the light of facts as he thought them to be (putative facts).[22: (1934) ILR 61, 64]

4) Social Danger Test

In order to distinguished and differentiate an act of attempt from an act of preparation the following factors are contributed.

A) The seriousness of the crime attempted;

B) The apprehension of the social danger involved.

In this test the accused’s conduct is no examined only partially but the consequences of the circumstances and the fullness of the facts are taken into consideration. For example, A administers some drugs to a pregnant woman in order to do abortion. However, they do not produce the result. In spite of this A would be held liable for an attempt from the view point of the social danger test, as his act would cause as alarm to society causing social repercussions.

5) The Equivocality test:

It is a situation wherein there are two opinions about the crime here, an attempt is an act of such a nature that it speaks for itself or that it is in itself evidence of the criminal intent with which it is done. A criminal attempt bears criminal intent upon its face. In other words, if what is done indicates unequivocally and beyond reasonable doubt the intention to commit the offence, it is an attempt, or else it is a mere preparation.


The Case of _State of Maharashtra v. Mohd.Yakub_ A jeep driven by the respondent and a truck was stopped at about midnight near a bridge. The respondents started removing the bundle from the truck. At this time customs officials acting on a clue reached the spot and accosted the respondents. At the same time, the sound of a mechanized sea-crafts engine was heard near the side of the creek. Two persons from the neighbourhood were called and in their presence silver ingots were recovered from the vehicles. Respondent no-1 had a pistol, a knife and some currency notes. On the questioning it was found that the respondents were not the dealers in silver.

The trial court convicted the accused u/s 135(1) (a) read with section 135(2) of the Customs Act for attempting to smuggle out of India silver ingots worth about Rs. 8 lakhs in violation of Foreign Exchange Regulation Act, the Imports and Exports (control) Act and the Custom Act. But the Additional session judge acquitted them on the ground that the facts proved by the prosecution fell short of establishing that the accused had ‘attempted’ to export silver in contravention of the Law. The High Court upheld the acquittal. The Supreme Court however allowed the appeal and set aside the acquittal.[23: (1980) 3 SCC 57]

The reasoning behind the imposition of responsibility for criminal attempts has been stated to be to control dangerous conduct or person. For the commission of crime by person involves four stages viz, formation of the intention or mental element, preparation for commission of crime, acting on the basis of preparation, commission of the act resulting in an event proscribed by law. To criminalize attempts these four stages are involved but the last stage fails to complete.

As stated by Kenny, criminal liability will not begin until the offender has done some act which not only manifests his mens rea but also goes some way towards carrying out it. In this regard, to commit offence of attempt mens rea, preparation and actus Reus are necessary values but the actus Reus is failed to be completed. These values generally criminalize the attempt and impose criminal liability on the person who commits the offence of Attempt.


Criminal conspiracy can be defined as ‘secret plan by a group of people to do something harmful or illegal’. The crime of conspiracy is comprised of an agreement between two or more persons to commit a criminal act. ‘Criminal law in some countries or for some conspiracies may require that at least one overt act must also have been undertaken in furtherance of that agreement, to constitute an offense. There is no limit on the number participating in the conspiracy and, in most countries, no requirement that any steps have been taken to put the plan into effect (compare attempts which require proximity to the full offence).

For the purposes of concurrence, the actus reus is a continuing one and parties may join the plot later and incur joint liability and conspiracy can be charged where the co-conspirators have been acquitted or cannot be traced’.Conspiracy has been defined in the US as an agreement of two or more people to commit a crime, or to accomplish a legal end through illegal actions.[24: Manser, M. H., & McGauran, F. (2005). c. In Oxford learner’s pocket dictionary (3rd Ed.). Oxford: Oxford University Press.][25: Conspiracy (criminal) – Wikipedia, the free encyclopaedia. Retrieved March 30, 2014, from][26: Conspiracy Law & Legal Definition. Retrieved from]

Section 120A of the Indian Penal Code 1860 say that members of criminal conspirators are jointly liable for the conspiracy to commit an offence and s 120B provides the punishment in such cases.the Supreme court held in the Krishna Govind Patil v State of Maharashtra that the pre-arranged plan may develop on the spot during the course of the omission of the offence but the crucial circumstances is that it must precede the act constituting the offence.

When on the shouts for help given by the complaint and the injured, others came to their rescue , all of them ran away together .the accused in the furtherance of that common intention began to remove the cheaper and when Ram ha rakh obstructed, they beat him and the others who came to resists their attack and aggression.[27: Gaur, H. S., Desai, M. C., Kumar, G., & Sethi, R. B. (2000). The penal law of India: Being an analytical, critical & expository commentary on the Indian Penal Code (Act XLV of 1860) as amended up to date (11th ed., pp. 1101-1131). Allahabad: Law Publishers.][28: AIR 1963 SC1413][29: Gaur, K. D. (2008). Preliminary crimes. In Criminal law: Cases and materials (5th ed., p. 237). New Delhi: LexisNexis Butterworths]

According to Indian Penal Code 1860 conspiracy is a substantive exists in the very agreement. Between two or more persons to commit a criminal offence, irrespective of the further consideration whether or not the offence has actually been committed.[30: Bimbadhar Pradhan v State of Orissa AIR 1956 SC 469]

Among the other inchoate offences criminal conspiracy is the most complicate can also be seemed to be arbitrary. ‘If the mere intention of one person to commit crime is not criminal, why should the agreement of two people to do it make criminal? The only possible reply is that the law is fearful of numbers, and that the act of agreeing to offend is regarded as such a decisive step as to justify its own criminal sanction.'[31: Williams, G. L. (1983). The General Part. In Textbook of criminal law (2nd ed., p. 420). London: Stevens’s sons.]


The actus Reus of criminal conspiracy is that entering to an agreement to commit crime. The mens rea of conspiracy is the intent to achieve the object of agreement. The House of Lords in Churchill v Walton held that in relation to strict offences the accused is guilty only if he knows of the circumstances. Accordingly, an agreement to commit a strict offence requires mens rea. There are mainly two types of conspiracy they are a chain conspiracy which involves communication and cooperation by individuals linked together in a vertical chain to achieve a criminal intent and next is a network type conspiracy which involves a single person or group that serves as a hub or common core connecting various individuals or spokes. ‘Following R v Churchill [1967] HL the Law Commission reported on Conspiracy and Criminal Law Reform (Law Com no 76):”What the prosecution ought to have to prove is that the defendant agreed with another person that a course of conduct should be pursued which would result, if completed, in the commission of a criminal offence, and further that they both knew any facts they would need to know to make them aware that the agreed course of conduct would result in the commission of the offence.

“This report led to the enactment of the Criminal Law Act 1977.Conspiracy imposes criminal liability on the basis of a person’s intention. This is a different harm from the commission of the substantive offence. The intention which is criminalised in the offence of conspiracy should itself be blameworthy, irrespective of the provisions of the substantive offence. A conspiracy is looking to the future. It is an agreement about future conduct. Section 1(1) Criminal Law Act 1977″…if a person agrees with any other person or persons that a course of conduct shall be pursued which, if the agreement is carried out in accordance with their intentions … (a) will necessarily amount to or involve the commission of any offence or offences by one or more of the parties to the agreement …he is guilty of conspiracy to commit the offence or offences in question.” The actus Reus of conspiracy is complete in the making of an agreement in which the parties intend to carry out their agreement. The offence is complete even if the parties do not carry out their agreement. The offence is complete even if the substantive offence is not thereafter committed by any of the conspirators or by anyone else.'[32:]

CRIMINAL OBJECTIVES[33: Lippmann M. (2010). Contemporary Criminal Law, 2nd Ed and Texas State Supplement for Lippmann’s Contemporary Criminal Law, 2nd Ed. Sage Pubns.]

a. Modern statutes generally limit the criminal objectives of conspiracy to agreements to commit crimes

b. Wharton’s Rule provides that an agreement by two persons to commit a crime requires the voluntary and cooperative actions of two persons that cannot constitute a conspiracy

c. The Gebardi rule provides that an individual who is in a class of persons that are excluded from criminal liability under a statute may not be charged with a conspiracy to violate the same law.

According to Indian Penal Code 1860, it contained only two provisions by which conspiracy was made punishable. Later in ‘mulcahy v r the judge ruled that 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, or to doe lawful means . So longs as such a design rest in the intention, only it is not 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 culpable of being enforced if lawful , punishable if for a criminal object or for the use of criminal means.'[34: (1860) LR 3 HL 306.]


Abetment of a crime means instigating, inciting or encouraging a crime. A person who engages in abetment of a crime is also punishable under law. An Abetment can take place in three ways they are abetment by Instigation, abetment by Conspiracy and abetment by Intentional Aiding. When an offence is committed by means of several acts, whoever intentionally cooperates in the commission of that offence by doing any one of those acts, either him or jointly with any other person an abetment happens. People who commit an abetment are titled as an abettor. ‘A person abets the doing of a thing, who-

Instigates any person to do that thing;

Engages with one or more other person or persons in any conspiracy for doing of fact 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

Intentionally aids, by any act or illegal omission, the doing of that thing.'[35: Gaur, K. D. (2008). Preliminary crimes. In Criminal law: Cases and materials (5th ed., p. 246). New Delhi: LexisNexis Butterworths.]


It is essential to note that when considering the law relating to abetment is the requirement of mens rea as a precondition of has been held in shrilal v state of Madhya breaththat in order to convict a person of abetting the commit ion of a crime, it is absolutely necessary to connect him with those steps of the transaction which are innocent, but in some way or other, it is absolutely necessary to connect him with those steps which are criminal.[36: AIR 1953 MB 155]


A person is said to be abettor when he commit offence that is entering an agreement with one or more persons to do a legal act by illegal manner. For an illustration A, a watchman of house enters in an agreement with the thief to keep open the gate of that house in night so that they might commit theft. An act or illegal omission should have taken place in pursuance of the conspiracy and in order for the commission of the conspiracy conspired for; in the latter offence , the mere agreement if it is one to commit an offence , is prove the charge of abetment by conspiracy , the prosecution is required to prove that the abettor has instigated the doing of a particular thing or engaged with one or more other person or persons in any conspiracy for the doing of that thing or intentionally aided by an act or illegal omission , doing that thing.[37: Atchuthen, P. P., Suresh, V., & Nagasaila, D. (2012). Abetment. In PSA Pillai’s Criminal law (11th ed., p. 204). New Delhi, India: LexisNexis Butterworths.]

INGREDIENTS OF ABETMENT [38: Atchuthen, P. P., Suresh, V., & Nagasaila, D. (2012). Abetment. In PSA Pillai’s Criminal law (11th ed., p. 210-211). New Delhi, India: LexisNexis Butterworths.]

Abetment of illegal omission is an offence

Abetted act need not be committed: effect of abetment is immaterial.

Person abetted need not be culpable of committing an offence

Abetment of an abetment is an offence

Abettor need not concert in abetment by conspiracy.


In _Faguna kanta Nath v state of Assam_ , One Narendra Nath was carrying paddy to sell in the market when he was obstruct by an inspector accompanied by appellant and two others and demanded Rs. 200 as bribe but he was forced to pay Rs 150 at the spot and to execute promissory note of Rs 70 in favour of the appellant. The appellant was tried and convicted under S 165A of Indian Penal Code 1860 for having abetted the Inspector for taking gratification other than legal remuneration in respect of an official act by the latter under s161. The High court maintained the conviction of the appellant. [39: AIR 1959SC 673]



Literally, solicitation means “urgently asking”. It is the action or instance of soliciting; petition; proposal. In criminal law, it most commonly refers to either the act of offering goods or services, or the act of attempting to purchase such goods or services. Legal status may be specific to the time and/or place where solicitation occurs.Solicitation can also be defined as commanding, hiring, or encouraging another person to commit a crime. Solicitation usually results in a punishment slightly less severe or equivalent to the crime solicited. ‘Criminal solicitation is requesting, encouraging or demanding someone to engage in criminal conduct, with the intent to facilitate or contribute to the commission of that crime’. [40: Solicitation – Wikipedia, the free encyclopaedia. . Retrieved March 31, 2014, from][41: Solicitation – Find Law. . Retrieved March 29, 2014, from]


The mens rea of solicitation requires a specific intent or purpose that another individual commit a crime. The _Actus Reus_ of solicitation requires an effort to get another person to commit a crime. The crime is complete, the moment the statement requesting another to commit a crime is made. A statement justifying or hoping is not sufficient; there must be an effort to get another person to commit a crime. An individual is guilty of solicitation even in instances that a letter asking others to commit a crime is intercepted and does not reach the intended target.


Though state laws vary, to be guilty of solicitation, one must request that someone else engage in criminal conduct and have an intention to engage in criminal conduct with that person. States vary as to whether the other person must receive the request, or whether the act of making the request (along with criminal intent) is enough to constitute solicitation. Some require that the other person actually receive the request. For example in case of solicitation of prostitution, this generally means that the person must communicate a request that another person engage in sex acts for compensation, and must have the intention to follow through with the request.


In the United States, the term “solicitation” implies some part of commercial element, consideration, or payment. In some other common law countries, the situation is different where the substantive offense is not committed, the charges are drawn from incitement, conspiracy, and attempt and where the substantive offense is committed, the charges are drawn from conspiracy, counselling and procuring, and the substantive offenses as joint principals. To an extent solicitation and incitement are similar but they are different.

‘Incitement was an offence under the common law of England and Wales. It was an inchoate offence.’ It consisted of persuading, encouraging, instigating, pressuring, or threatening so as to cause another to commit a crime. In England, The law commission in its consultation paper no. 131, assisting and encouraging crime, 1993 proposed the abolition of incitement and by new offence of encouraging crime. [42: Baker, D. J., & Williams, G. L. (2012). Textbook of criminal law. London: Sweet & Maxwell.][43: Jefferson, M. (2005). Inchoate offences. In Criminal law (7th ed., p. 370). Harlow: Pearson Longman.]


The rationale of incitement matches the general justification underpinning the other inchoate offences of conspiracy and attempt by allowing the police to intervene before a criminal act are completed and the harm or injury is actually caused. There is considerable overlap, particularly where two or more individuals are involved in criminal activity. The plan to commit crime may exist only in the mind of one person until others are incited to join in, at which point the social danger becomes more real. The offence overlaps the offences of counselling or procuring as an accessory. Indeed, in the early case of _R v Higgins_ incitement was defined as being committed when one person counsels, procures or commands another to commit a crime, whether that person commits the crime.[44: Incitement – Wikipedia, the free encyclopaedia. . Retrieved March 31, 2014, from]


An inchoate crime can also be defined as ‘A crime committed by doing an act with the purpose of affecting some other offence’. ‘In conclusion attempt can be said to be a general inchoate offense on a statutory basis and abolishing the common law offence of attempt it can also been drawn that indictable offence can be criminally attempted .the statutory provisions should me made recognising that a criminal attempt can be committed by omission where the target offence in the circumstances of the attempt can be committed by omission .the agreement in conspiracy can be established where only one party has criminal capacity.

Abolition of spousal immunity rule in conspiracy is much needed provision. Conspiracy can attach to incitement but not to attempt or conspiracy. In case of incitement the formula “command encourages requests, or otherwise seeks to influence” another to commit a crime is used to define the act of incitement. The inchoate offence with exception of attempt can be incited but charges that certain more than two layers of inchoate liability should not be constructed’. And finally inchoate offences can also be termed as Preliminary crimes or Anticipatory crime.[45: Baker, D. J., & Williams, G. L. (2012). Textbook of criminal law. London: Sweet & Maxwell.][46: Ireland. Law Reform Commission (1998). Report on privacy: Surveillance and the interception of communications. Dublin: Law Reform Commission.]




















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