The law of complicity, particularly relating to joint enterprise liability, appears to becoming more and more complicated. Cases on secondary liability for murder in the Court of Appeal demonstrate that this area of law is difficult to interpret and to apply. Even more complex is the question of how to apply these cases to offences other than murder. This case note attempts to address the Court of Appeal's questions in the case of R v Martin as to how the jury ought to be directed in a case of aiding and abetting causing death by dangerous driving.