Defendant 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.
Defendant 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.