Okla. Stat. » Title 21 — CRIMES AND PUNISHMENTS
Oklahoma Statutes

Okla. Stat. tit. 21, § 172 (2026)

Principals defined

✓ current as of July 2026
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All persons concerned in the commission of crime, whether it be felony or misdemeanor, and whether they directly commit the act

constituting the offense, or aid and abet in its commission, though not present, are principals. R.L.1910, § 2104.

Notes of Decisions
Cited in 86 cases (6 in the last 5 years), 1954–2025 · leading case: VanWoundenberg v. State, 720 P.2d 328 (Okla. Crim. App. 1986).
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VanWoundenberg v. State, 720 P.2d 328 (Okla. Crim. App. 1986). · cites it 4× “Title 21 O.S.1981, § 172 provides: All persons concerned in the commission of crime, whether it be felony or misdemeanor, and whether they directly commit the act constituting the offense, or aid and abet in its commission, though not present, are principals.”
Williams v. Trammell, 782 F.3d 1184 (10th Cir. 2015). · cites it 2× “Okla. Stat. Ann. tit. 21, § 172 (“All persons concerned in the commission of crime, whether it be felony or misdemeanor, and whether they directly commit the act constituting the offense, or aid and abet in its commission, though not present, are principals.”
Huckaby v. State, 804 P.2d 447 (Okla. Crim. App. 1990). · cites it 4× “21 O.S.1981, § 172. The liabilities between accessories before the fact and principals are no longer distinguishable.”
Conover v. State, 933 P.2d 904 (Okla. Crim. App. 1997). · cites it 2× “1984); 21 O.S.1991, § 172. Mere presence or acquiescence, without participation, does not constitute a crime.”
Powell v. State, 2000 OK CR 5 (Okla. Crim. App. 2000). · cites it 2× “1984); 21 O.S.1991, § 172. Mere presence or acquiescence, without participation, does not constitute a crime.”
Frye v. State, 606 P.2d 599 (Okla. Crim. App. 1980). · cites it 2× “” The theory advanced by the State is that there was sufficient circumstantial evidence to prove that appellant Collins committed an overt act aiding and abetting the murder plot, thus rendering her a principal in the crime under 21 O.S.1971, § 172. The State’s case, in addition…”
Torres v. Mullin, 317 F.3d 1145 (10th Cir. 2003). “See Okla. Stat. tit. 21, § 172 (stating that persons “concerned in the commission of crime, .”
Lockett v. State, 2002 OK CR 30 (Okla. Crim. App. 2002). “He complains in his second proposition that the evidence was insufficient to support his conviction on these counts. In order for an accused to be convicted as a principal to a crime, it must be established that he directly committed each element of the offense, or that he aided…”
Postelle v. State, 267 P.3d 114 (Okla. Crim. App. 2011). “Under 21 O.S.2001, § 172, all persons who directly commit the act constituting the offense or aid and abet in its commission, even if not present, are principals and can be charged as an accomplice and held eriminally *127 liable.”
Glossip v. State, 2007 OK CR 12 (Okla. Crim. App. 2007). “21 O.S.2001, § 172. Aiding and abetting requires the State to show "the accused procured the crime to be done, or aided, abetted, advised or encouraged the commission of the crime.”
Hammon v. State, 2000 OK CR 7 (Okla. Crim. App. 2000). · cites it 2× “" Title 21 O.S.1991, § 172 says: "All persons concerned in the commission of crime, whether it be felony or misdemeanor, and whether they directly commit the act constituting the offense, or aid and abet in its commission, though not present, are principals.”
Nova Health Sys. v. Edmondson, 460 F.3d 1295 (10th Cir. 2006). “See Okla. Stat. tit. 21, § 172 . . Nova provides abortions through the 17th week of pregnancy.”
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