R. v. Duong, 1998 CanLII 7124 (ON C.A.)
[19] A charge a laid under s. 23(1) must allege the commission of a specific offence (or offences) and the Crown must prove that the alleged accessory knew that the person assisted was a party to that offence. The Crown will meet its burden if it proves that the accused had actual knowledge of the offence committed. Whether wilful blindness will suffice is addressed below. The further question of whether recklessness as to the offence committed by the principal would be sufficient need not be decided in this case.
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