1.  He was accused of attempting to overthrow the government using unlawful means.

2.  The judge ruled that Smith had been elected by unlawful means.

3.  The money was obtained by unlawful means.

4.  They had entered the country by unlawful means.

5.  The protests came as some right-wing opposition legislators urged Israelis to use unlawful means to fight against the emerging accord on a troop withdrawal and Palestinian elections.