The co-conspirators exception to the hearsay rule may apply to all indictments for crime and is not confined to an indictment for conspiracy, Koufis v. The King 1941 CanLII 55 (SCC), [1941] S.C.R. 481 (S.C.C.) - For the exception to apply, there must be independent evidence admissible against an accused alone implicating him in the common design or joint enterprise.
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