concurring and dissenting:
The majority holds that a citizen may use force to defend himself/herself or another against police brutality only if the use of excessive force by the police threatens death or serious bodily injury. In the meantime, i.e., until the excessive force approaches a level which threatens death or serious bodily injury, the citizen must suffer a police beating without resistance. I dissent. Such a result is not consistent with the provisions of the Crimes Code and, in my judgment, establishes an unfortunate precedent.
Appellant contended at trial that the police had been the aggressors and had used excessive force in confronting the group of which she was a part. She argued that her striking of Officer Welsh had been justified because she acted to protect Moran, her boyfriend, from injury because of the beating being inflicted upon him by the police. Her evidence was that the group of which she had been a part had been attacked by several black youths, all but one of whom had fled when the police arrived. Thereafter, she contended, the police had beaten Moran and Haughey. Moran, appellant said, had been struck repeatedly by police nightsticks about the head, shoulders and ribs, and when *458she intervened he was turning colors because a policeman had placed a foot on his throat. Appellant testified further that Moran’s lip had been bleeding, his eye had become swollen and he had sustained cracked ribs. In response to appellant’s evidence, the trial court instructed the jury regarding the defense of justification in the following manner:
Now, in this case justification is a defense, if the defendant French reasonably believed that her intervention was necessary to protect Moran from death or serious bodily injury and that the force used was immediately necessary to protect Moran against the force used by Officer Welsh on the same occasion as Miss French used force.
Because the Commonwealth has the burden of disproving the defense of justification, you may find Miss French guilty only if you are satisfied beyond a reasonable doubt either that French did not reasonably believe that her intervention was necessary to protect Moran or that she did not reasonably believe that the force she used was immediately necessary to protect Moran then and there against the force used by Officer Welsh, (emphasis added)
The issue of first impression raised by appellant on appeal is whether the trial court, by its instruction, improperly limited the defense of justification to cases in which intervention is necessary to protect the actor or another person from death or serious bodily injury because of police use of excessive force. After careful review of the Crimes Code and judicial decisions in other states, I would hold that the trial court erroneously interpreted the Crimes Code and improperly limited the right of a citizen to protect himself/herself or another against the use of excessive force by the police.
The use of force in protecting other persons is governed by 18 Pa.C.S. § 506, which provides generally that a person is justified in using force to protect another person under the same circumstances and to the same extent that he or *459she would be justified in using force to protect himself or herself. Pursuant to 18 Pa.C.S. § 505, a person is justified in using force to protect himself or herself “when the actor believes that such force is immediately necessary for the purpose of protecting himself [or herself] against the use of unlawful force by such other person on the present occasion.” 18 Pa.C.S. § 505(a). However, the use of force is not justifiable “to resist an arrest which the actor knows is being made by a peace officer, although the arrest is unlawful....” 18 Pa.C.S. § 505(b)(1)(i).
Subsection 505(b)(1)(i) of the Pennsylvania Crimes Code is identical to the language of Section 3.04(2)(a)(i) of the Model Penal Code. The comment to the Model Penal Code distinguishes between the use of force to resist an illegal arrest and the use of force to resist excessive force by the police in making any arrest. The Comment is as follows:
It should of course be noted, however, that the limitation forbids the use of force for the sole purpose of preventing an arrest; it has no application when the actor apprehends bodily injury, as when the arresting officer unlawfully employs or threatens deadly force, unless the actor knows that he is in no greater peril than arrest if he submits to the assertion of authority. The actor thus does not lose his justification if the officer uses more force than is necessary to effect the arrest, or otherwise constitutes a danger to the safety of the citizen.
Model Penal Code § 3.04, Comment at p. 43 (emphasis added). It follows that while the defense of self-defense is not available to one who resists an arrest which is made unlawfully but without excessive force, it is available to one who is subjected to police use of excessive force in making an arrest, even where the arrest is otherwise lawful. When a citizen is subjected to excessive force at the hands of the police, he or she may use that degree of force which is reasonably necessary to protect himself or herself from bodily injury.
*460“Bodily injury” is defined by the Crimes Code as “[impairment of physical condition or substantial pain.” 18 Pa.C.S. § 2301. “Serious bodily injury” is limited to “[b]odily injury which creates a substantial risk of death or which causes serious, permanent disfigurement, or protracted loss or impairment of the function of any bodily member or organ.” 18 Pa.C.S. § 2301. The majority holds that a citizen may use reasonable force to protect himself or herself only where police use of excessive force threatens serious bodily injury. I would hold that reasonable force may also be used to protect a citizen from excessive police force which threatens bodily injury. The police do not have a right, in making an arrest, to inflict bodily injury by using excessive force.
Toll, in his invaluable work on the Pennsylvania Crimes Code, has observed that 18 Pa.C.S. § 505(b)(1)(i) “has no application when [the person being arrested] apprehends bodily injury, as when the arresting officer unlawfully employs or threatens deadly force, unless the actor knows that he is in no peril greater than arrest if he submits to the assertion of authority.” Toll, Pennsylvania Crimes Code Annotated § 505(b)(1)(i) at p. 166 (emphasis added). Toll’s reference to “deadly force” is illustrative and not restrictive of the exception which pertains to the right to resist an arresting officer’s improper use of excessive force which threatens injury to the person being arrested.
In a majority of jurisdictions, which, like Pennsylvania, prohibit the use of force to resist an illegal arrest,1 the defense of justification is available to persons who have used reasonable force to protect themselves or others against the use of excessive force by the police. Thus in State v. Mulvihill, 57 N.J. 151, 270 A.2d 277, 44 A.L.R.3d 1071 (1970), the Supreme Court of New Jersey held that *461although a person does not have a privilege to resist an arrest made by one he knows to be an authorized police officer, an arrested person may use reasonable force to protect himself from the use of excessive and unnecessary force by the arresting officer. The New Jersey Court observed that “the rule permitting reasonable resistance to excessive force [by] the officer, whether the arrest is lawful or unlawful, is designed to protect a person’s bodily integrity and health and so permits resort to self-defense. Simply stated, the law recognizes that liberty can be restored through legal processes but life or limb cannot be repaired in a courtroom. And so it holds that the reason for outlawing resistance to an unlawful arrest and requiring disputes over its legality to be resolved in the courts has no controlling application on the right to resist an officer’s excessive force.” Id. at 156-58, 270 A.2d at 280, 44 A.L.R.3d at 1075.
The law in New York is also that “a citizen may use reasonable force in self-defense where the force exerted by the police in effecting an arrest is excessive.” People v. Stevenson, 31 N.Y.2d 108, 112, 335 N.Y.S.2d 52, 56, 286 N.E.2d 445, 448 (1972). And in Commonwealth v. Moreira, 388 Mass. 596, 600-01, 447 N.E.2d 1224, 1227 (1983), the Supreme Judicial Court of Massachusetts held that “in the absence of excessive or unnecessary force by an arresting officer, a person may not use force to resist an arrest by one who he knows or has good reason to believe is an authorized police officer, engaged in the performance of his duties, regardless of whether the arrest was unlawful in the circumstances.” (emphasis added). See also: Gray v. State, 463 P.2d 897 (Alaska 1970); People v. Curtis, 70 Cal.2d 347, 74 Cal.Rptr. 713, 450 P.2d 33 (1969); People v. Hess, 687 P.2d 443 (Colo.1984); State v. Holley, 480 So.2d 94 (Fla.1985); People v. Bailey, 108 Ill.App.3d 392, 64 Ill.Dec. 75, 439 N.E.2d 4 (1982); State v. Franz, 9 Kan.App.2d 319, 676 P.2d 157 (1984); State v. Nunes, 546 S.W.2d 759 (Mo.App.1977); City of Columbus v. Fraley, 41 Ohio St.2d 173, 324 N.E.2d 735 (1975), cert. denied, 423 U.S. 872, 96 S.Ct. 138, 46 L.Ed.2d 102 (1975); State v. Crane, 46 *462Or.App. 547, 612 P.2d 735 (1980); State v. Gelinas, 417 A.2d 1381 (R.I.1980); State v. Peters, 141 Vt. 341, 450 A.2d 332 (1982); State v. Reinwand, 147 Wis.2d 192, 433 N.W.2d 27 (1988); Best v. State, 736 P.2d 739 (Wyo.1987). Contra: State v. Westlund, 13 Wash.App. 460, 536 P.2d 20 (1975). See: Annot., Right to Resist Excessive Force Used in Accomplishing Lawful Arrest, 77 A.L.R.3d 281 (1977).
It may be that appellant and her co-defendants were the aggressors in their skirmish with the- police and that their use of force was not necessary to defend themselves against the force, if any, exercised by the police. Because she asserted in defense that the use of force was necessary to protect against excessive force used by the police, however, appellant was entitled to have the jury correctly instructed. I would hold that the jury was not correctly instructed. I am unable to join the majority which, under the shibboleth of serving “the interests of peace in society,” has fashioned a rule which unnecessarily limits principles of self-defense defined by the legislature in the Crimes Code and which, because of its precedential effect, may work a manifest injustice in future cases. Thus, if excessive force were used by police to arrest a citizen who mistakenly was identified as a wanted felon, the citizen, under the rule adopted by the majority, would be required to endure a beating without defending himself or herself unless or until he or she were threatened with death or “serious, permanent disfigurement, or protracted loss or impairment of the function of [a] bodily member or organ.” Moreover, if the citizen surrendered to the natural tendency to defend himself or herself against excessive police force rather than passively accepting a beating, he or she would be deprived of the defense of self-defense if it were subsequently determined that excessive police force threatened only bodily injury and not serious bodily injury. A rule which permits such a result, in my judgment, is dangerous and not at all what the legislature intended when it adopted sections 505 and 506 of the Crimes Code.
*463The application of normal principles of self-defense to situations where police use excessive force will not, as the majority suggests, “encourage unnecessary violence” or “invite ... escalating retaliatory conduct.” The statute defining the justification defense has included limitations which will prevent the use of force and violence by persons who are arrested by the police. Before a citizen is justified in using even slight force against a police officer, the citizen must have a reasonable belief that such force is immediately necessary to protect himself/herself or another against bodily injury inflicted as a result of excessive force used by the police. The degree of force permitted in self-defense, moreover, would be only that force reasonably necessary to protect against bodily injury. I am confident that the law of self-defense as defined by the legislature will be adequate to preserve the public peace and protect police officers against citizen violence in the performance of their duties. It will also serve to protect citizens against the use of excessive force by the police.
After careful review of the history of the Pennsylvania Crimes Code and the decisions interpreting similar statutory language by the courts of sister states, I am persuaded that the trial court’s instruction on self-defense was erroneous. Appellant was entitled to receive an instruction that her use of force was justified if she believed that such force was immediately necessary to protect her companion against an arresting officer’s use of excessive force which was likely to cause bodily injury to such other person. I would hold that excessive force by an arresting officer may justifiably be resisted if such excessive force is likely to cause any impairment of another’s physical condition or substantial pain. The use of force to protect against an officer who unlawfully uses excessive force to make an arrest should not be limited to those situations in which the excessive force is likely to cause death or serious bodily injury.
I agree with the majority’s determination that the trial court erred when it refused defense counsel the right to examine statements made by police officers during an inves*464tigation of the incident by the Internal Affairs Division. Examination of these statements had been requested by defense counsel to assist in cross-examining the several police officers who testified against appellant at trial. The court requested that the statements be produced, made an in-camera examination of the statements, concluded that they contained no exculpatory information, and denied appellant’s request that her counsel be allowed to examine them. Appellant argues on appeal that the officers’ statements should have been examined through the eyes of an advocate and that the trial court erroneously denied her counsel access to the same.
In Commonwealth v. Contakos, 492 Pa. 465, 472, 424 A.2d 1284, 1288 (1981), the Pennsylvania Supreme Court stated that “a defendant is entitled to review any notes, reports or written records relating to interviews with witnesses who subsequently testify at trial.” The reasons for allowing defense access to prior statements of Commonwealth witnesses were explained in Commonwealth v. Hamm, 474 Pa. 487, 378 A.2d 1219 (1977), where the Court said:
[I]n Pennsylvania, a defendant is entitled, upon request at trial, to examine prior statements of Commonwealth witnesses which the Commonwealth has in its possession. Commonwealth v. Grayson, 466 Pa. 427, 353 A.2d 428 (1976); Commonwealth v. Johnson, 457 Pa. 554, 327 A.2d 632 (1974) (dictum); Commonwealth v. Morris, 444 Pa. 364, 281 A.2d 851 (1971); Commonwealth v. Kontos, supra. Examination of these statements provides the defense “a fair opportunity to cross-examine the witnesses.” Commonwealth v. Grayson, 466 Pa. at 429, 353 A.2d at 429; accord, Jencks v. United States, 353 U.S. 657, 667, 77 S.Ct. 1007, 1012-13, 1 L.Ed.2d 1103, 1111 (1957).
We conclude that in camera review of the prior statements of Commonwealth witnesses by the trial court does not adequately protect the interests served by permitting *465the defense access to prior statements of Commonwealth witnesses.
We believe that defense counsel can better evaluate whether the prior statements relate to the subject matter of a witness’ direct testimony. Statements which on their face do not appear to bear upon the direct testimony may actually be relevant once defense counsel brings to the court’s attention other information counsel has developed through his investigation and preparation of the defense. We recognize that the trial court has the ultimate responsibility to determine whether the prior statements may be used in cross-examining the witness or are otherwise admissible. However, like other evidentiary rulings, these determinations are properly made in an adversary context. We do not believe that the trial court can determine the value that prior statements may have to the defense without hearing defense argument after inspection. See Jencks v. United States, 353 U.S. at 669 & n. 14, 77 S.Ct. at 1013-14 & n. 14.
We hold that upon request at trial, the defense is entitled to examine in their entirety the prior statements of Commonwealth witnesses which the Commonwealth has in its possession. We recognize that there may be situations in which defense access to prior statements should be restricted by the trial court, but the availability of protective orders should be adequate in such situations. Upon a showing of good cause by the Commonwealth, the trial court may issue a protective order limiting the defense right to examine the statements of Commonwealth witnesses. See generally Commonwealth v. Kontos, 442 Pa. at 350 n. 6, 276 A.2d at 833 n. 6; Lewis v. Court of Common Pleas, [436 Pa. 296, 260 A.2d 184] supra; (1969) ABA Standards §§ 2.5(b), 2.6, 4.4.
Id., 474 Pa. at 496-501, 378 A.2d at 1223-1226 (footnotes omitted). More recently the Court reaffirmed this reasoning in Commonwealth v. Lloyd, 523 Pa. 427, 567 A.2d 1357 *466(1989). See also: Commonwealth v. Gartner, 475 Pa. 512, 381 A.2d 114 (1977); Commonwealth v. Grayson, 466 Pa. 427, 353 A.2d 428 (1976); Commonwealth v. Kontos, 442 Pa. 343, 276 A.2d 830 (1971); Commonwealth v. Meo, 362 Pa.Super. 328, 524 A.2d 902 (1987).
A case factually similar to the instant case was before the Supreme Court in Commonwealth v. Smith, 417 Pa. 321, 208 A.2d 219 (1965). There the defendant had been stopped by a police officer for a traffic violation, and a fight between the officer and the defendant had ensued. At trial the defendant contended that the officer had been the aggressor and that he, the defendant, had acted only in self-defense. The officer refuted this testimony, stating that defendant had struck the first blow. The officer’s testimony was corroborated in part by the testimony of two eyewitnesses who testified that defendant had appeared to be the aggressor. During trial, the defendant requested a subpoena to compel production of statements previously made by the witnesses to F.B.I. personnel who had investigated defendant’s complaint that the police had violated his civil rights. The trial court refused to issue the subpoena. On appeal following conviction, the Supreme Court held that the defendant should have been provided access to the witnesses’ statements and ordered a new trial. The lead opinion, authored by Justice Musmanno and joined by one other justice, concluded that this result was compelled by the compulsory process clause of the United States Constitution. In a concurring opinion, three justices concluded, on non-constitutional grounds, that the interests of justice required disclosure of the witnesses’ prior statements.
Recently, in Commonwealth v. Lloyd, supra, the Supreme Court cited Smith with approval. In Lloyd, the defendant had been charged with raping and sexually abusing a six year old child. At trial he sought access to records of the victim’s psychotherapeutic treatment in order to substantiate a defense claim that the victim had been hallucinatory or delusional. After viewing the records in camera, the trial court determined that defendant’s claims *467were unfounded and denied access to the records. The Supreme Court reversed. In holding that the defense should have been given access to the records, the Supreme Court said:
We now hold under the confrontation clause of the Pennsylvania Constitution, that the appellant in the instant action was denied his right to confrontation when his attorney was denied access to the contents of the victim’s psychotheraputic [sic] records. In addition we hold that the right to inspect these records is also mandated by the compulsory process clause of the Pennsylvania Constitution. Our reasoning in this regard is guided by this Court’s decision in Commonwealth v. Smith, 417 Pa. 321, 208 A.2d 219 (1965). In Smith the issue was whether the defendant had the right to inspect certain witness statements in the possession of the Federal Bureau of Investigation. While discussing the appellant’s right to access this information, Justice Musmanno writing for the majority stated, “Smith had the right to, and great need for, the statements he requested. The 6th Amendment to the Constitution of the United States guarantees to the accused the right to have compulsory process for obtaining witnesses in his favor and to have the assistance of Counsel for his defense.” Smith, Pa. at 329, 208 A.2d at 223. Though the issue in Smith was resolved under the United States Constitution, it is clear that the Court intended to afford similar protection under the Pennsylvania Constitution when it said, “Of course, Article 1, section 9 of the Pennsylvania Constitution is equally applicable.” Smith, 417 Pa. at 329 N. 2, 208 A.2d at 223 N. 1a.
Commonwealth v. Lloyd, supra, 523 Pa. at 432-33, 567 A.2d at 1359.
It seems abundantly clear, therefore, that defense counsel was entitled to examine prior statements made by the arresting police officers during the investigation of the incident by the Internal Affairs Division. When the trial court refused to grant access to these prior statements by *468Commonwealth witnesses, it fell into error. This error was not remedied by the trial court’s examination of the statements or by its failure to find exculpatory material therein. Appellant was entitled to have them examined through the eyes of an advocate. I would grant a new trial to correct this error. See: Commonwealth v. Lloyd, supra; Commonwealth v. Smith, supra.
Appellant also contends that the trial court erred when it refused to permit cross-examination of the arresting officers regarding the investigation made by Internal Affairs. The trial court’s ruling, she contends, was a denial of her right to confront the Commonwealth’s witnesses with possible motives for lying about the incident.
The right of confrontation includes the right to cross-examine witnesses about possible motives for testifying falsely. Commonwealth v. Dawson, 486 Pa. 321, 323-324, 405 A.2d 1230, 1231 (1979). This includes the right to show that a witness has an interest, direct, or collateral, in the result of the trial. Commonwealth v. Evans, 511 Pa. 214, 225-226, 512 A.2d 626, 632 (1986); Commonwealth v. Cheatham, 429 Pa. 198, 202-203, 239 A.2d 293, 296 (1968); Commonwealth v. Shands, 338 Pa.Super. 296, 302-303, 487 A.2d 973, 976-977 (1985). See also: Davis v. Alaska, 415 U.S. 308, 94 S.Ct. 1105, 39 L.Ed.2d 347 (1974). The scope and limits of cross-examination, however, are within the discretion of the trial court, whose rulings thereon will not be reversed absent an error of law or abuse of discretion. Commonwealth v. Rivers, 383 Pa.Super. 409, 416, 557 A.2d 5, 9 (1989); Commonwealth v. Ross, 345 Pa.Super. 571, 574, 498 A.2d 972, 973 (1985). See also: Commonwealth v. Lane, 492 Pa. 544, 424 A.2d 1325 (1981); Commonwealth v. Cheatham, supra.
In Commonwealth v. Sullivan, 485 Pa. 392, 402 A.2d 1019 (1979), the defendant was charged with hindering apprehension and simple assault arising out of a confrontation with a police officer who was attempting to arrest his son. Following the confrontation, the officer was suspended pending the determination of criminal charges against *469the defendant. At trial, defendant sought to cross-examine the officer regarding his suspension, but the trial court sustained an objection thereto. The Supreme Court held that the trial court had erred, reasoning as follows:
In making this ruling, the trial court denied appellant his right of confrontation which includes the right to cross-examine witnesses about possible motives to testify. Commonwealth v. Dawson [486 Pa. 321, 405 A.2d 1230 (1979);] Commonwealth v. Cheatham, 429 Pa. 198, 239 A.2d 293 (1968). Appellant was entitled to question the police officer to illustrate whether he had an interest in the outcome of the case. This interest may have given the witness a motive in testifying and appellant had a right to explore this.
Commonwealth v. Sullivan, supra 485 Pa. at 394, 402 A.2d at 1020.
A similar result was reached in Commonwealth v. Dawson, supra, where a homicide detective testified that the defendant had confessed. The defendant maintained that the detective had fabricated the confession to provide an alibi for himself during the period of time in which the detective had allegedly beaten a co-defendant. The defendant was not permitted to cross-examine the detective regarding the alleged beating of the co-defendant or about the detective’s subsequent transfer from the homicide division, which the defendant contended was the result of disciplinary action against the detective. The Supreme Court held the trial court’s ruling was erroneous and a denial of the defendant’s constitutional right to cross-examine witnesses appearing against him. The Court reasoned:
In the instant case, [the detective’s] alleged misconduct and disciplining could have motivated him to fabricate the confession or otherwise give false testimony. Evidence thereon would have been relevant to his motivation and credibility. It was improper not to allow appellant’s proposed cross-examination.
Id. 486 Pa. at 324, 405 A.2d at 1231. See also: Commonwealth v. Shands, supra (defendant had right to cross-ex*470amine arresting police officers regarding ongoing state and federal investigation into their conduct in similar cases, especially where prosecutor doubted the veracity of the officers in prior prosecutions).
Thus, the law is clear that a criminal defendant must be permitted to cross-examine police witnesses against him regarding investigations pending with respect to possible misconduct by the officers or disciplinary actions taken against them as a result of the incident which is the subject of the charges against the defendant. Such matters may demonstrate bias or prejudice which a jury may consider in determining the weight to be given to the witness’s testimony.
In the instant case, however, the Internal Affairs investigation had been completed prior to the trial of the charges against appellant, and the charges of police misconduct had been found to be unsubstantiated. The arresting officers, therefore, had been cleared and were not subject to future sanctions. Thus, the completed Internal Affairs investigation was no longer relevant to demonstrate that the police officers had an interest in the outcome of the criminal charges against appellant.
Not only was appellant allowed to cross-examine the police witnesses fully about their handling of the incident resulting in her arrest, but Moran also testified about the complaint which he had filed with the Internal Affairs Division. The exclusion of further cross-examination regarding the investigation, under the circumstances, was neither erroneous nor an abuse of discretion. It did not deprive appellant of the right to cross-examine witnesses against her. As I have previously observed, however, it was error for the court to prevent appellant from examining prior statements made by the police witnesses regarding the incident. Such statements are not privileged. Cross-examination with respect to prior inconsistent statements made by a witness, if any, is invariably proper cross-examination.
*471With respect to appellant’s remaining issues, I am essentially in agreement with the majority. Appellant contends that the Commonwealth failed to prove beyond a reasonable doubt the existence of an agreement between her and her companions to commit the crimes of aggravated assault and resisting arrest. She argues, rather, that the evidence, even when viewed in the light most favorable to the Commonwealth, demonstrated no more than “an unplanned, impromptu fracas on the street among appellant’s friends and some police officers, and appellant’s unsolicited attempts to intervene during the struggle.”
The crime of conspiracy is defined by statute as follows:
§ 903. Criminal conspiracy
(a) Definition of conspiracy.—A person is guilty of conspiracy with another person or persons to commit a crime if with the intent of promoting or facilitating its commission he:
(1) agrees with such other person or persons that they or one or more of them will engage in conduct which constitutes such crime or an attempt or solicitation to commit such crime; or
(2) agrees to aid such other person or persons in the planning or commission of such crime or of an attempt or solicitation to commit such crime.
18 Pa.C.S. § 903(a). “The essence of a criminal conspiracy is a common understanding, no matter how it came into being, that a particular criminal objective be accomplished.” Commonwealth v. Keefer, 338 Pa.Super. 184, 190, 487 A.2d 915, 918 (1985). See also: Commonwealth v. Plusquellic, 303 Pa.Super. 1, 449 A.2d 47 (1982); Commonwealth v. Anderson, 265 Pa.Super. 494, 402 A.2d 546 (1979). “Shared criminal intent is a sine qua non of the crime of conspiracy.” Commonwealth v. Snyder, 335 Pa.Super. 19, 34, 483 A.2d 933, 941 (1984). See also: Commonwealth v. Schomaker, 501 Pa. 404, 461 A.2d 1220 (1983); Commonwealth v. Wilson, 449 Pa. 235, 296 A.2d 719 (1972). “Although a person participates in a criminal activity which is the object of the conspiracy, his actions will not support a conviction *472for conspiracy without proof of an agreement and participation pursuant to that agreement.” Commonwealth v. Derr, 501 Pa. 446, 450, 462 A.2d 208, 210 (1983). See also: Commonwealth v. Yobbagy, 410 Pa. 172, 188 A.2d 750 (1963); Commonwealth v. Holman, 237 Pa.Super. 291, 352 A.2d 159 (1975).
[I]n order to convict a defendant of conspiracy, a factfinder must conclude that he reached an agreement with his co-conspirator to commit the crime. Commonwealth v. Graves, 316 Pa.Super. 484, 463 A.2d 467 (1983). Direct proof of the corrupt agreement, however, is not necessary. Commonwealth v. Brown, 351 Pa.Super. 119, 505 A.2d 295 (1986). “An explicit or formal agreement to commit crimes can seldom, if ever, be proved and it need not be, for proof of a criminal partnership is almost invariably extracted from the circumstances that attend its activities.” Commonwealth v. Campbell, 353 Pa.Super. 178, 509 A.2d 394 (1986) quoting Commonwealth v. Strantz, 328 Pa. 33, 43, 195 A. 75, 80 (1937). Thus, the existence of a common agreement between co-conspirators may be inferred from circumstantial evidence surrounding the allegedly conspiratorial activities, and from the relationship between and the conduct of the parties. Commonwealth v. Gordon, 329 Pa.Super. 42, 477 A.2d 1342 (1984).
Commonwealth v. Anderson, 381 Pa.Super. 1, 15-16, 552 A.2d 1064, 1071 (1988). See also: Commonwealth v. Kennedy, 499 Pa. 389, 453 A.2d 927 (1982); Commonwealth v. Carter, 329 Pa.Super. 490, 478 A.2d 1286 (1984); Commonwealth v. Davenport, 307 Pa.Super. 102, 452 A.2d 1058 (1982).
Among the circumstances which are relevant, but not sufficient by themselves, to prove a corrupt confederation are: (1) an association between alleged conspirators; (2) knowledge of the commission of the crime; (3) presence at the scene of the crime; and (4) in some situations, participation in the object of the conspiracy. The presence of such circumstances may furnish a web of evi*473dence linking an accused to an alleged conspiracy beyond a reasonable doubt when viewed in conjunction with each other and in the context in which they occurred. Commonwealth v. Carter, 272 Pa.Super. 411, 416 A.2d 523 (1979).
Commonwealth v. Lamb, 309 Pa.Super. 415, 429, 455 A.2d 678, 685-686 (1983). See also: Commonwealth v. Cooke, 342 Pa.Super. 58, 492 A.2d 63 (1985); Commonwealth v. Olds, 322 Pa.Super. 442, 469 A.2d 1072 (1983); Commonwealth v. Anderson, 265 Pa.Super. 494, 402 A.2d 546 (1979).
Appellant relies upon a decision by the Supreme Court in Commonwealth v. Kennedy, supra. In that case, following an argument, the defendant and a companion beat the defendant’s landlord, causing his death. The Supreme Court reversed a conviction for conspiracy, concluding that there had been insufficient evidence to establish a conspiracy. The Court reasoned that
[m]ore than mere association of participants in crime must be shown. Commonwealth v. Eiland, 450 Pa. at 570, 301 A.2d at 652; Commonwealth v. Roux, 465 Pa. 482, 488, 350 A.2d 867, 870 (1976). Thus, persons do not commit the offense of conspiracy when they join into an affray spontaneously, rather than pursuant [to] a common plan, agreement, or understanding. Id.; Commonwealth v. Wilson, 449 Pa. 235, 296 A.2d 719 (1972).
Id., 499 Pa. at 395-396, 453 A.2d at 930. Thus, the Court held, the mere escalation of an argument into a beating which caused the death of the victim did not, without evidence of an agreement to commit an assault, establish the common understanding or agreement necessary to a criminal conspiracy. Cf. Commonwealth v. Wilson, supra 449 Pa. at 239, 296 A.2d at 721 (“[W]here a third party decides on his own initiative to become a participant in an affray between two others and without any request or encouragement, he alters radically the nature and course of the encounter, there can be no nexus of common intent to fasten vicarious criminal liability for the third party’s acts on the initial participants.”).
*474Although Kennedy is undoubtedly good law, there are in the instant case additional facts which require careful analysis. Here, appellant and her companions were already engaged in a concerted effort to beat a young, black male when police arrived. After police intervened and told the group to disperse, appellant and her companions jointly hurled epithets at and verbally abused the police. While Haughey and Moran were engaged in fisticuffs with the police and resisted police efforts to subdue them, appellant continued to shout obscenities at the police. After Haughey and Moran had been placed under arrest and handcuffed, appellant walked up to Officer Welsh and struck him before she, too, was placed under arrest. And while she and her companions were being transported to the police station, they continued to shout obscenities. This evidence showed a continuous series of acts committed in concert by appellant and her companions. The conduct by appellant, a jury could find, was more than a mere spontaneous entry into an affray.
An agreement to engage in illegal activity may be tacit; it requires no extended period of time but can be formed almost instantaneously. Here, a jury could find that the foursome, which included appellant, acted in concert to bring about the confrontation with the police and appellant, by design, went to the aid of her co-conspirators when their activity resulted in their being placed under arrest. Therefore, I agree with the majority’s conclusion that the evidence was sufficient to permit a jury to find that appellant was part of a criminal confederation.
The information charging appellant with conspiracy identified no specific victim and alleged generally that appellant had been part of a conspiracy to engage in resisting arrest and assaulting police. In view of the general nature of the averments of the information, it was not error for the trial court to fail to charge that the conspiracy had to be directed specifically toward an assault on Officer John Welsh and resistance to an arrest which he had attempted to make.
*475The trial court also did not err when it refused appellant’s requested point for charge regarding the use of prior inconsistent statements in assessing witness credibility. “As a general rule, ‘[t]he refusal to give a proper instruction requested by a party is ground for a new trial only if the substance thereof has not otherwise been covered by the trial court’s general charge.’ ” Commonwealth v. LaMassa, 367 Pa.Super. 54, 58, 532 A.2d 450, 452 (1987), quoting Werner v. Quality Service Oil Co., Inc., 337 Pa.Super. 264, 269, 486 A.2d 1009, 1011 (1984). Here, the trial court adequately instructed the jury regarding the credibility of witnesses. Moreover, the court told the jury, inter alia, that in determining credibility it should consider whether a witness had contradicted himself or had been contradicted by other witnesses.2
By way of summary, I would affirm the trial court’s refusal to arrest judgment. However, I would reverse and remand for a new trial because the trial court incorrectly instructed the jury on the applicability of the justification defense after appellant had testified that she acted to defend her companion. I would also grant a new trial because the trial court erred when it denied access by defense counsel to statements made by police witnesses during an Internal Affairs investigation. I find no merit in appellant’s remaining assignments of error.
. At common law a privilege existed to use force to resist an illegal arrest. See: 5 Am.Jur.2d, Arrest, § 94; Annot. Modern Status of Rules as to Right to Forcefully Resist Illegal Arrest, 44 A.L.R.3d 1078 (1972). The modern trend, however, is to prohibit the use of force to resist arrests which are technically unlawful. See: Commonwealth v. Moreira, 388 Mass. 596, 447 N.E.2d 1224 (1983); Wharton’s Criminal Law, Vol. 4, § 593 (14th ed. 1981).
. Appellant also complains that the trial court incorrectly defined for the jury the crimes of conspiracy and aggravated assault. These issues, however, were waived. When the charge to the jury came to an end, the trial court asked if counsel wished any changes or adjustments. Appellant’s counsel, when given an opportunity to do so, did not object to or seek a correction of the court’s definitions of conspiracy and aggravated assault. If specific objections had been made, the trial court would have had an opportunity to correct any error which may have crept into its jury instructions. In the absence of a timely objection, the alleged definitional errors in the charge were waived. See: Commonwealth v. Galloway, 495 Pa. 535, 538, 434 A.2d 1220, 1221 (1981); Commonwealth v. Brown, 490 Pa. 560, 570, 417 A.2d 181, 187 (1980); Commonwealth v. Martinez, 475 Pa. 331, 337-338, 380 A.2d 747, 750-751 (1977); Commonwealth v. Larkins, 340 Pa.Super. 56, 66-67, 489 A.2d 837, 842-843 (1985); Commonwealth v. Rineer, 310 Pa.Super. 241, 246-249, 456 A.2d 591, 593-595 (1983). See also: Pa.R.Crim.P. 1119(b).