It is not only the perpetrator who will be liable for the criminal offence. Other participants in the offence may also be liable. In English law, section 8 of the Accessories and Abettors Act 1861 (amended by the UK Criminal Law Act 1967) states: “Whosoever shall aid, abet, counsel or procure the commission of any indictable offence, whether the same be an offence at common law or by virtue of any Act passed or to be passed, shall be liable to be tried, indicted and punished AS A PRINCIPAL OFFENDER” The PRINCIPAL is the main perpetrator of the criminal offence: the one who commits the actus reus or the substantial part of the actus reus. There can be more than one principal if more than one person is directly responsible for the actus reus. The test is whether someone contributes to the actus reus by his or her own independent act rather than merely aiding or abetting. A person may be charged with just aiding and abetting a murder. A person may be charged with counselling and procuring a murder, or with aiding, abetting, counselling and procuring a murder. “Aiding” means assisting the principal offender to commit the offence. “Abetting” means providing encouragement, either physically, psychologically, or emotionally-in that the principal offender draws encouragement from the abettor. “Counselling” the principal offender means giving advice prior to the commission of the murder, even if the counsellor is not present at the murder scene. “Procuring” means “producing the end offence (of the shooting) by endeavour” and constitutes secondary participation in the murder. A PERSON MAY BE CHARGED WITH “PARTICIPATING IN THE MURDER” IF THAT PERSON COULD HAVE PREVENTED THE MURDER, BY INFORMING THE POLICE OF PLANS MADE. THAT PERSON MAY NOT HAVE SHOWN VIOLENCE BUT THAT PERSON HAD THE MENS REA AS TO THEIR OWN ACTIONS OR LACK OF ACTIONS AND SO THAT PERSON HAD KNOWLEDGE OF, OR AT LEAST WILFUL BLINDNESS AS TO THE CIRCUMSTANCES OF DAN MARKEL'S MURDER.