ABSTRACT

Magda Pniewska (V) was walking home from work across a South London car park talking to her sister by phone. Suddenly and shockingly she was dead, killed by a bullet fired by someone known only as 'Bandana Man' (P) in the reports of R v Gnango. The bullet had been directed at Armel Gnango (D) who had responded to a shot from P by firing back at him, prompting several exchanges of gun fire, an event described as a 'shoot-out' in judgments shortly to be scrutinised. The impact of Gnango on parasitic accessory liability, direct or 'true' accessory liability and the conception of principal offenders will be examined in that sequence. In this chapter, Lord Phillips and Lord Judge are referencing the temptations for prosecutors to resort to joint enterprise in cases of multi-party violence.