There are some crimes that requires more than two individuals who participate in committing such crimes in two opposite ways and criminal code provides that the performer is punished for committing them(one- sided criminality). It is one of the controversial issues whether it is possible to apply general provisions on accomplice liability to such crimes. Korean Supreme Court is taking a stance that only the performer can be punished for committing those crimes and it is not allowed to punish the accomplice through application of general rules on accomplice liability. For example Supreme Court decision 2011Do6287 decided November 13, 2011 applied that principle judging two-way criminality between doctors who issued false prescriptions and a taker who instigated the doctors to issues false prescriptions and ruled that the doctors(the issuers) are the only criminal and the other part(the taker) is free from that crime. But the Supreme Court rulings is facing some heavy criticisms that it is not resonable that the taker who instigated the doctors to divulge issued false prescriptions should be punished as an instigator and the Supreme Court’s stance will result in inequality between the principal offender and others actively involved.This article deals with problems concerning the liability of accomplice in one-sided criminality and proposes some solutions for them.

Looking at the 2000s, the Supreme Court has no detailed research on legal issues, leave the judgment of the past and the trend seems to quote. For example, errors of law in the judgment of a legitimate reason, joint principal offender the functional activity of the dominant theory of criminal law theory, Studies of accumulated information, we accept them gradually is moving in the direction. But the Supreme Court include the specific criteria are difficult to understand the concept and are using them. Nevertheless, the fact that by missing arguments for the inclusion of judgment comes to the conclusion lacks a logical basis for a problem that is leaving. The concept of morals and social standards for the presentation of an abstract interpretation and judgment, collusion joint principal offender beliefs about the uncritical criticism of scholars for the future through careful research accumulated in Criminal Justice Studies, by accepting the theory and practice of will have to endeavor to harmonize. Thinking and knowledge learned in courses to apply it in practice will need to prevent useless. Korean Association of Criminal Case Studies is celebrating its 20th anniversary, criticism of the theory and practice through the mutual development to be able to look forward to continue to evolve.