A criminal conspiracy is defined in Mulcahy v. R. (1868), L.R. 3 H.L. 306, as follows [p. 317]: “A conspiracy consists not merely in the intention of two or more, but in the agreement of two or more to do an unlawful act, or to do a lawful act by unlawful means”. In civil conspiracy, this definition is modified to the extent that there must be some action taken in pursuance of the agreement and this action must result in injury to the plaintiff.
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