The ambit of ‘fraud’ in conspiracy to defraud
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The potential width of this offence can be seen from the fact that the relevant agreement need not be to commit a substantive offence such as theft. For instance, in one case, the defendants used the facilities of their employer to dye items to profit themselves and not their employer. They were convicted of conspiracy to defraud their employer of the profit even though the employer had no proprietary interest in the profit capable of being ‘stolen’.172 The agreement may instead be to cause another person to act contrary to his public duty, for instance by granting an official licence of some sort.173