Hawkins, an American saxophone player, played at a concert in London with four French musicians in violation of Article 18(s) of the Aliens Order of 1920. Herbert William Wilcox (defendant) was a reporter for a British magazine called Jazz Illustrated who was covering the performance. Wilcox covered the arrival of Hawkins and the others at the airport, purchased a concert ticket, and attended the performance. There was no evidence that Wilcox actually applauded Hawkins’ playing, nor any evidence that he protested the performance. Subsequently, Wilcox wrote an article for the magazine, praising the event. A magistrate found that Wilcox had aided and abetted Hawkins’ violation of the Aliens Order, and he appealed.