CONSPIRACY LAW ACROSS BORDERS: A LEGAL COMPARISON BETWEEN NIGERIA AND THE COMMONWEALTH

Abstract

English law encompasses inchoate offences, crimes that address conduct before the full commission of a substantive crime. One such inchoate offence is conspiracy. This paper delves into the examination of conspiracy across three Commonwealth jurisdictions: Nigeria, India, and the Australian State of Queensland. The foundation for this exploration is the English legal system, the source of common law, given that these three jurisdictions base their legal systems on English common law principles. While the English legal system lays the groundwork, the analysis extends to the regulation of conspiracy in each jurisdiction. In Nigeria, the Penal Code and the Criminal Code govern this offence, while in India, the Indian Penal Code provides the legal framework. In the Australian State of Queensland, the Criminal Code of 1899, which influenced the Nigerian Criminal Code, serves as the guiding statute. This comparative analysis aims to shed light on the varying approaches to conspiracy in these Commonwealth jurisdictions and their alignment with English law principles