Criminal law – Conspiracy. The Court of Appeal, Criminal Division, held that, on its true construction, s 2(2)(a) of the Criminal Law Act 1977 extended to a spouse under a polygamous marriage recognised under English law as valid. Accordingly, two of the defendants' appeals against a conviction of conspiracy to facilitate the breach of immigration law were dismissed. Where the first defendant had been domiciled in the United Kingdom at the time of the polygamous marriage, that marriage, therefore, had been held invalid under English law, thus, not providing them with an exemption from liability for the offence of conspiracy.