The principal in the first degree would be the person who committed all or part of the physical elements of the crime. To be prosecuted it would be necessary to demonstrate that the principal in the first degree committed the actus reus with adequate mens rea. Example: if person A used a gun to rob a store, he would be the first degree instigator since he committed the crime himself. In Cooper v Regina [2011] NSWCCA 258, the appellant, Bradley Cooper, was arraigned on a charge of murdering Dale Kevin Muldoon on 22 March 2003. In this case, Cooper would be the first degree principal as he delivered all the blows to the deceased's head and was therefore solely responsible for the murder. However, according to a variant of the definition, a person can be charged as a first degree principal if they possess the mens rea but cause an innocent person to commit physical