R v Griffiths [1969] 1 QB 589
Conspiracy – Knowledge of Co-Conspirators – Fraud
Facts
The defendant was a seller of limes who entered into a conspiracy with seven lime farmers to defraud the Ministry of Agriculture by submitting fraudulent subsidy claims. Each of the farmers had entered into this fraudulent agreement with the defendant, but there was no evidence to suggest that any of them were even aware of the existence of the other farmers and were not aware that they were also part of a single conspiracy. Instead, the evidence suggested that the lime dealer himself had entered into the same agreement with several different lime farmers at the same time. All however were charged with a single count of conspiracy and convicted. They appealed.
Issues
Whether there was a single conspiracy to commit fraud on the ministry between all of the defendants considering their lack of knowledge of the other conspirators. Whether the defendants should have been charged with separate charges of conspiracy with the lime supplier instead.
Decision/Outcome
The appeals were allowed and the convictions quashed. As there was no evidence that the lime farmers were aware of the conspiracy between the other farmers and the lime seller, they could not be guilty of a single conspiracy. Instead, each should have been charged with a separate count of conspiracy between themselves and the lime seller. In law, for a single conspiracy, all conspirators must join the one agreement, each with the others in order to constitute the conspiracy. Each may join at any time, and whilst they do not have to know the other conspirators, they have to be aware that there are other conspirators.
Updated 20 March 2026
This case summary accurately reflects the decision in R v Griffiths [1969] 1 QB 589 and the legal principles it established regarding the requirements for a single conspiracy. The core principle — that all parties to a single conspiracy must be aware that others are involved, even if they do not know their identities — remains good law. It is worth noting that the law of criminal conspiracy is now primarily governed by the Criminal Law Act 1977, which post-dates this case. Section 1 of that Act defines statutory conspiracy, and the common law conspiracy to defraud (relevant to the facts of Griffiths) continues to exist alongside it, preserved by section 5(2) of the 1977 Act. The principles from Griffiths concerning the structure of a single conspiracy continue to be applied in modern cases involving complex or multi-party conspiracies. The article remains a reliable statement of the relevant common law principles, though readers should be aware that the statutory framework now provided by the 1977 Act is the primary source of conspiracy law in England and Wales.
