Common Purpose
   HOME

TheInfoList



OR:

The doctrine of common purpose, common design, joint enterprise, joint criminal enterprise or parasitic accessory liability is a
common law In law, common law (also known as judicial precedent, judge-made law, or case law) is the body of law created by judges and similar quasi-judicial tribunals by virtue of being stated in written opinions."The common law is not a brooding omnipres ...
legal doctrine A legal doctrine is a framework, set of rules, Procedural law, procedural steps, or Test (law), test, often established through precedent in the common law, through which judgments can be determined in a given legal case. A doctrine comes about w ...
that imputes
criminal liability In law, liable means "responsible or answerable in law; legally obligated". Legal liability concerns both civil law and criminal law and can arise from various areas of law, such as contracts, torts, taxes, or fines given by government agenci ...
to the participants in a criminal enterprise for all reasonable results from that enterprise. The common purpose doctrine was established in
English law English law is the common law legal system of England and Wales, comprising mainly criminal law and civil law, each branch having its own courts and procedures. Principal elements of English law Although the common law has, historically, be ...
, and later adopted in other common-law
jurisdiction Jurisdiction (from Latin 'law' + 'declaration') is the legal term for the legal authority granted to a legal entity to enact justice. In federations like the United States, areas of jurisdiction apply to local, state, and federal levels. Jur ...
s including
Scotland Scotland (, ) is a country that is part of the United Kingdom. Covering the northern third of the island of Great Britain, mainland Scotland has a border with England to the southeast and is otherwise surrounded by the Atlantic Ocean to the ...
,
Ireland Ireland ( ; ga, Éire ; Ulster Scots dialect, Ulster-Scots: ) is an island in the Atlantic Ocean, North Atlantic Ocean, in Northwestern Europe, north-western Europe. It is separated from Great Britain to its east by the North Channel (Grea ...
,
Australia Australia, officially the Commonwealth of Australia, is a Sovereign state, sovereign country comprising the mainland of the Australia (continent), Australian continent, the island of Tasmania, and numerous List of islands of Australia, sma ...
,
Trinidad and Tobago Trinidad and Tobago (, ), officially the Republic of Trinidad and Tobago, is the southernmost island country in the Caribbean. Consisting of the main islands Trinidad and Tobago, and numerous much smaller islands, it is situated south of ...
, the
Solomon Islands Solomon Islands is an island country consisting of six major islands and over 900 smaller islands in Oceania, to the east of Papua New Guinea and north-west of Vanuatu. It has a land area of , and a population of approx. 700,000. Its capita ...
,
Texas Texas (, ; Spanish language, Spanish: ''Texas'', ''Tejas'') is a state in the South Central United States, South Central region of the United States. At 268,596 square miles (695,662 km2), and with more than 29.1 million residents in 2 ...
,
Massachusetts Massachusetts (Massachusett language, Massachusett: ''Muhsachuweesut assachusett writing systems, məhswatʃəwiːsət'' English: , ), officially the Commonwealth of Massachusetts, is the most populous U.S. state, state in the New England ...
, the
International Criminal Court The International Criminal Court (ICC or ICCt) is an intergovernmental organization and international tribunal seated in The Hague, Netherlands. It is the first and only permanent international court with jurisdiction to prosecute individuals ...
, and the
International Criminal Tribunal for the former Yugoslavia The International Criminal Tribunal for the former Yugoslavia (ICTY) was a body of the United Nations that was established to prosecute the war crimes that had been committed during the Yugoslav Wars and to try their perpetrators. The tribunal ...
. Common design also applies in the law of tort. It is a different legal test from that which applies in the criminal law. The difference between common designs in the criminal law and the civil law was illustrated in ''NCB v Gamble''
959 Year 959 ( CMLIX) was a common year starting on Saturday (link will display the full calendar) of the Julian calendar. Events By place Byzantine Empire * April - May – The Byzantines refuse to pay the yearly tribute. A Hungari ...
1 QB 11 at 23, by Devlin LJ: The difference applies in US law as well. The United States Supreme Court reached the same conclusion in ''Sony Corporation of America v Universal City Studios Inc.'' 464 US 417 (1984). The supply of equipment for copying video cassettes did not give rise to joint liability in tort for copyright infringement. There was no encouragement to copy music and therefore no liability as an accessory. The difference lies between mere knowledge at the point of sale and action combined with common intention: ''Metro-Goldwyn-Mayer Studios Inc. v Grokster Ltd.'' 545 US 913 (2005): see p. 931. A different result was reached in ''Metro-Goldwyn-Mayer'' by the US Supreme Court. There was a common design there because the defendants "distribute a device with the object of promoting its use to infringe copyright". That test was satisfied because clear statements and positive steps were taken by the administrators of the website to encourage infringement. A common application of the rule is to impute criminal liability for wounding a person to participants in a riot who knew, or were reckless as to knowing, that one of their number had a knife and might use it, despite the fact that the other participants did not have knives themselves. In
England and Wales England and Wales () is one of the three legal jurisdictions of the United Kingdom. It covers the constituent countries England and Wales and was formed by the Laws in Wales Acts 1535 and 1542. The substantive law of the jurisdiction is Eng ...
and certain other
Commonwealth countries The Commonwealth of Nations is a voluntary association of 56 sovereign states. Most of them were British colonies or dependencies of those colonies. No one government in the Commonwealth exercises power over the others, as is the case in a po ...
, this was the understanding of the courts until February 2016, when the
Supreme Court of the United Kingdom The Supreme Court of the United Kingdom (initialism: UKSC or the acronym: SCOTUK) is the final court of appeal in the United Kingdom for all civil cases, and for criminal cases originating in England, Wales and Northern Ireland. As the Unite ...
and the
Judicial Committee of the Privy Council The Judicial Committee of the Privy Council (JCPC) is the highest court of appeal for the Crown Dependencies, the British Overseas Territories, some Commonwealth countries and a few institutions in the United Kingdom. Established on 14 Augus ...
jointly ruled in ''
R v Jogee was a 2016 judgment of the Supreme Court of the United Kingdom that reversed previous case law on joint enterprise. The Supreme Court delivered its ruling jointly with the Judicial Committee of the Privy Council, which was considering an appeal ...
'' that it was wrong, and that nothing less than intent to assist the crime would do.


Jurisdictions


English law

An old example of this doctrine in
English law English law is the common law legal system of England and Wales, comprising mainly criminal law and civil law, each branch having its own courts and procedures. Principal elements of English law Although the common law has, historically, be ...
is ''R v Swindall and Osborne'' (1846) 2 Car. & K. 230. Two cart drivers engaged in a race. One of them ran down and killed a pedestrian. It was not known which one had driven the fatal cart, but since they were encouraging each other in the race, it was irrelevant which of them had actually struck the man and both were held jointly liable. Thus the parties must share a common purpose and make it clear to each other by their actions that they are acting on their common intention, so that each member of the group assumes responsibility for the actions of the whole group. When this happens, all that flows from the execution of the plan makes them all liable. This is a question of causation, in that oblique intention will be imputed for intermediate consequences that are a necessary precondition to achieving the ultimate purpose, and liability will follow where there are accidental and unforeseen departures from the plan, so long as there is no ''
novus actus interveniens Novus ("new" in Latin) may refer to: Companies * Novus Biologicals, a biotech company based in Littleton, Colorado, US * Novus Entertainment, a Canadian telecommunications company * Novus International, an animal health and nutrition company * Nov ...
'' to break the chain. Until 2016, in cases where there is violence beyond the level anticipated, the prosecution had to prove: In ''
R v Jogee was a 2016 judgment of the Supreme Court of the United Kingdom that reversed previous case law on joint enterprise. The Supreme Court delivered its ruling jointly with the Judicial Committee of the Privy Council, which was considering an appeal ...
'' 016/nowiki> UKSC 8 the UK Supreme Court decided that (c) was wrong, and that the prosecution actually had to prove that D had intended to assist A to commit the crime, and this normally meant (but did not have to mean) that D intended A to commit the crime.


Deliberate departure

Where one of the participants deliberately departs from the common purpose by doing something that was not authorised or agreed upon, that participant alone is liable for the consequences. In the situation exemplified in ''Davies v DPP''
954 Year 954 ( CMLIV) was a common year starting on Sunday (link will display the full calendar) of the Julian calendar. Events By place Europe * Spring – A Hungarian army led by Bulcsú crosses the Rhine. He camps at Worms in th ...
AC 378, a group comes together for a fight or to commit a crime, and either the participant knows or does not know that one of the group has a weapon. If the person knows that there is a weapon, it is foreseeable that it might be used and the fact that the other participants do not instruct the one carrying to leave it behind means that its use must be within the scope of their intention. However, if the person does not know of the weapon, this is a deliberate departure from the common purpose and this breaks the enterprise.


When the outcome is death

The simplest form of joint enterprise to
murder Murder is the unlawful killing of another human without justification (jurisprudence), justification or valid excuse (legal), excuse, especially the unlawful killing of another human with malice aforethought. ("The killing of another person wit ...
is two or more planning to cause death and doing so. If all the parties participated in carrying out the plan, all are liable, regardless of who actually inflicted the fatal injury. However, when there is no plan to murder and one party kills while carrying out a plan to do something else, such as a planned robbery in which the participants hope to be able to get what they want without killing anyone, but one of them in fact kills, the other participants may still be guilty of murder or
manslaughter Manslaughter is a common law legal term for homicide considered by law as less culpable than murder. The distinction between murder and manslaughter is sometimes said to have first been made by the ancient Athenian lawmaker Draco in the 7th cen ...
if they had the necessary ''
mens rea In criminal law, (; Law Latin for "guilty mind") is the mental element of a person's intention to commit a crime; or knowledge that one's action (or lack of action) would cause a crime to be committed. It is considered a necessary element ...
''. In '' R v Craig & Bentley'' (1953), Derek Bentley was hanged for the murder of a police officer, committed in the course of a burglary attempt. The murder was committed by a friend and accomplice of Bentley's, Christopher Craig, then aged 16. Bentley was convicted as a party to the murder, by
English law English law is the common law legal system of England and Wales, comprising mainly criminal law and civil law, each branch having its own courts and procedures. Principal elements of English law Although the common law has, historically, be ...
principle of common criminal purpose "joint enterprise". The judge in court ( Lord Chief Justice Goddard) sentenced Bentley to death based on an interpretation of the phrase "Let him have it" (Bentley's alleged instruction to Craig), describing Bentley as "mentally aiding the murder of
Police Constable A constable is a person holding a particular office, most commonly in criminal law enforcement. The office of constable can vary significantly in different jurisdictions. A constable is commonly the rank of an officer within the police. Other peop ...
Sidney Miles". In 1998, Bentley received a posthumous pardon. In ''R v Lovesey and Peterson'' (1969) 530 million. App. R. 461, a gang was executing a plan to overpower a jeweller and steal his more valuable stock. After the robbery, the jeweller was found dead. All were properly convicted of murder because the death was the outcome of the agreed use of violence. That this accidentally caused the jeweller's death did not prevent liability. The usual case will involve plans to commit
criminal damage Property damage (or cf. criminal damage in England and Wales) is damage or destruction of Real property, real or tangible Personal property, personal property, caused by negligence, Willful violation, willful destruction, or Act of God, act of na ...
, burglary, rape or some other crime, and there will be no compelling inference that there must also have been a plan to kill. For the participants to be convicted of murder, the question becomes one of foresight that one of them might kill. In ''R v Powell (Anthony) and English''
999 999 or triple nine most often refers to: * 999 (emergency telephone number), a telephone number for the emergency services in several countries * 999 (number), an integer * AD 999, a year * 999 BC, a year Books * ''999'' (anthology) or ''999: T ...
1 AC 1, the House of Lords said that the other participants must have realised that, in the course of the joint enterprise, the primary party might kill with intent to do so or with intent to cause grievous bodily harm: with the intent necessary for murder. Thus, the Powell and English doctrine extends joint enterprise liability from the paradigm case of a plan to murder to the case of a plan to commit another offence in the course of which the possibility of a murder is foreseen (see R v Bryce. 2004). In ''Attorney General's Reference (No. 3 of 2004)'' (2005) EWCA Crim 1882, the defendant, H, was charged with manslaughter. H had sent K and C to terrify R, knowing both that K and C would have a loaded firearm with them, and that this firearm might be fired near R to increase his fear. The Court of Appeal held that H's liability depended on the scope of the joint enterprise. On the assumed facts, there was no evidence that H foresaw that the gun would be fired and R might be injured. Rather, K's intentional act of firing the gun so as to kill or cause R grievous bodily harm was fundamentally different from the acts contemplated by H. The outcome would have been different if there had been a common design to cause some harm to R. In such a case, H would be liable for manslaughter because, albeit to frighten, he had authorised the firing of the gun: he would have realised that K might intentionally cause some harm when he fired the gun. However, on the assumed facts, H did not foresee the possibility of any harm to R, let alone intentional harm, so he was properly acquitted. In ''
R v Gnango ''Regina v Armel Gnango'' is the leading English criminal law case on the interaction of joint enterprise, transferred malice, and exemption from criminal liability where a party to what would normally be a crime is the victim of it. The Suprem ...
'' 011UKSC 59, the
Supreme Court A supreme court is the highest court within the hierarchy of courts in most legal jurisdictions. Other descriptions for such courts include court of last resort, apex court, and high (or final) court of appeal. Broadly speaking, the decisions of ...
held that D2 is guilty of the offence of murdering V if (1) D1 and D2 voluntarily engage in fighting each other, each intending to kill or cause grievous bodily harm to the other and each foreseeing that the other has the reciprocal intention, and if (2) D1 mistakenly kills V in the course of the fight. Baker argues that the case was wrongly decided because it did not rest on oblique intention, invoked joint-perpetration where there was none, invoked the "provocative act murder doctrine where it did not apply, and overly restricted the incidental party/victim rule without seeing that it did not apply because the actual victim as opposed to the putative victim (Gnango) did not consent to being harmed." In ''
R v Jogee was a 2016 judgment of the Supreme Court of the United Kingdom that reversed previous case law on joint enterprise. The Supreme Court delivered its ruling jointly with the Judicial Committee of the Privy Council, which was considering an appeal ...
'' 016UKSC 8, the Supreme Court decided that intent, not mere foresight, must be proved to convict an accomplice of a crime of specific intent, such as murder. The court said "foresight of what might happen is ordinarily no more than evidence from which a jury can infer the presence of a requisite intention. It may be strong evidence, but its adoption as a test for the mental element for murder in the case of a secondary party is a serious and anomalous departure from the basic rule, which results in over-extension of the law of murder." He summarised the law as: "If the crime requires a particular intent, D2 must intend ... to assist D1 to act with such intent." (This appeal was heard jointly with an appeal from Jamaica to the
Judicial Committee of the Privy Council The Judicial Committee of the Privy Council (JCPC) is the highest court of appeal for the Crown Dependencies, the British Overseas Territories, some Commonwealth countries and a few institutions in the United Kingdom. Established on 14 Augus ...
, with the same judges, ''Ruddock v The Queen'' 016UKPC 7.)


Repentance

One person who has been an active member of a group with a common purpose may escape liability by withdrawing before the others go on to commit the crime. Mere repentance without any action, however, leaves the party liable. To be effective, the withdrawing party must actively seek to prevent the others from relying on what has been done. In ''R v Becerra'' (1975) 62 Crim. App. R. 212 it was held that any communication of withdrawal by the secondary party to the perpetrator must be such as to serve "unequivocal notice" upon the other party to the common purpose that, if he proceeds upon it, he does so without the further aid and assistance of the withdrawing party.: * If an accomplice only advised or encouraged the principal to commit the crime, he must at least communicate his withdrawal to the other parties. * Where an accomplice has supplied the principal with the means of committing the crime, the accomplice must arguably neutralise, or at least take all reasonable steps to neutralise, the aid he has given. * In more serious cases, it may be that the only effective withdrawal is either physical intervention or calling in the police. In ''R v Rook'' (1997) Cr. App. R. 327, the court held that, as in the case of joint enterprise where both parties are present at the scene of the crime, it is not necessary for the prosecution to show that a secondary party who lends assistance or encouragement before the commission of the crime intended the victim to be killed, or to suffer serious injury, provided it was proved that he foresaw the event as a real or substantial risk and nonetheless lent his assistance. Rook was convicted as one of a gang of three men who met and agreed the details of a
contract killing Contract killing is a form of murder or assassination in which one party hires another party to kill a targeted person or persons. It involves an illegal agreement which includes some form of payment, monetary or otherwise. Either party may be ...
of the wife of a fourth man on the next day. Rook did not turn up the next day and the killing was done by his two fellows. His defence was that he never intended the victim to be killed and believed that, if he failed to appear, the others would not go through with the plan. Lloyd LJ. described the evidence against him in this way: This did not amount to an unequivocal communication of his withdrawal from the scheme contemplated at the time he gave his assistance.


Hong Kong law

I
''Chan Wing-siu''
a criminal appeal from the
Supreme Court of Hong Kong The Supreme Court of Hong Kong was the highest court in Hong Kong prior to the transfer of sovereignty of Hong Kong from the United Kingdom to the People's Republic of China in 1997 and heard cases of first instance and appeals from the Di ...
, the
Privy Council A privy council is a body that advises the head of state of a state, typically, but not always, in the context of a monarchic government. The word "privy" means "private" or "secret"; thus, a privy council was originally a committee of the mon ...
held that if D1 and D2 set out to commit an offence (crime A), and in the joint of the enterprise, D1 commits another offence (crime B) beyond the scope of the plan, and D2 could foresee the commission of crime B (rather than real intention), D2 would be guilty as an accomplice of crime B. At the time of this judgement, Hong Kong was still a
British colony The British Overseas Territories (BOTs), also known as the United Kingdom Overseas Territories (UKOTs), are fourteen territories with a constitutional and historical link with the United Kingdom. They are the last remnants of the former Bri ...
, and under the
Hong Kong Basic Law The Basic Law of the Hong Kong Special Administrative Region of the People's Republic of China is a national law of China that serves as the organic law for the Hong Kong Special Administrative Region (HKSAR). Comprising nine chapters, 160 ...
, most case law, including ''Chan Wing-siu'', is retained as Hong Kong law after the
handover In cellular telecommunications, handover, or handoff, is the process of transferring an ongoing call or data session from one channel connected to the core network to another channel. In satellite communications it is the process of transfe ...
. In UK, ''Chan Wing-siu'' was jointly overturned by the
Supreme Court A supreme court is the highest court within the hierarchy of courts in most legal jurisdictions. Other descriptions for such courts include court of last resort, apex court, and high (or final) court of appeal. Broadly speaking, the decisions of ...
and the
Privy Council A privy council is a body that advises the head of state of a state, typically, but not always, in the context of a monarchic government. The word "privy" means "private" or "secret"; thus, a privy council was originally a committee of the mon ...
in ''Jogee'', as it is wrong, as a matter of law, to equates "foresight" with "intention to assist or encourage", the right direction is that "foresight" will be nothing more than evidence from which the jury could infer intention as to crime B. In Hong Kong, however, the Court of Final Appeal, i
''Chan Kam-shing''
refused to follow ''Jogee'', as it thought "abolition of the joint criminal enterprise doctrine would leave a serious gap in the law of criminal complicity", and "the concept of conditional intent introduced in the ''Jogee'' decision caused conceptual and practical difficulties". Therefore, the ''Chan Wing-siu'' principle is still good law in Hong Kong. In a landmark decision ,
Secretary for Justice v Tong Wai Hung
', the Court of Final Appeal clarifies the approach for determining principal liability for unlawful assembly and riot, held that the ''Chan Wing-siu'' principle is not applicable to the unlawful assembly and riot.


Controversy

The use of this doctrine has caused concern among academics and practitioners in the legal community and has been the subject of an investigation by the House of Commons Justice Select Committee in the UK. In 2010, a campaign group was formed in the UK called JENGbA (Joint Enterprise: Not Guilty by Association), which seeks reform of the law and supports those convicted by this means. JENGbA asserts that the misapplication of the principle constitutes a form of human rights abuse. On 6 July 2014, ''
Common Common may refer to: Places * Common, a townland in County Tyrone, Northern Ireland * Boston Common, a central public park in Boston, Massachusetts * Cambridge Common, common land area in Cambridge, Massachusetts * Clapham Common, originally com ...
'', a 90-minute television drama written by
Jimmy McGovern James Stanley McGovern (born September 1949) is an English screenwriter and producer. He is best known for creating the drama series '' Cracker'' (1993–1995), for which he received two Edgar Awards from the Mystery Writers of America. He als ...
, was shown on
BBC One BBC One is a British free-to-air public broadcast television network owned and operated by the BBC. It is the corporation's flagship network and is known for broadcasting mainstream programming, which includes BBC News television bulletins, p ...
. It examined the issues surrounding a case of joint enterprise or common unlawful purpose murder. On 7 July 2014, a documentary regarding a number of joint enterprise cases, ''Guilty by Association'', was also shown on
BBC One BBC One is a British free-to-air public broadcast television network owned and operated by the BBC. It is the corporation's flagship network and is known for broadcasting mainstream programming, which includes BBC News television bulletins, p ...
. One of these cases is that of Alex Henry, convicted in March 2014 at the Old Bailey alongside Janhelle Grant-Murray and Cameron Ferguson, for the murder of Taqui Khezihi and the non-fatal stabbing of Bourhane Khezihi. The court heard how Alex Henry was shopping in Ealing Broadway on a Tuesday afternoon in August 2013 with his two co-defendants. He exited the shopping centre with Ferguson to see Grant-Murray being confronted by a group of four older men who were unknown to all defendants. CCTV showed that Grant-Murray was holding a wine bottle by the neck and Bourhane Khezihi had removed his belt to use as a
knuckle duster Brass knuckles (variously referred to as knuckles, knucks, brass knucks, knucklebusters, knuckledusters, knuckle daggers, English punch, iron fist, paperweight, or a classic) are "fist-load weapons" used in hand-to-hand combat. Brass knuckles ...
. A combination of CCTV evidence and mobile phone video footage was used to piece together the 47-second affray in which Alex Henry can be seen running into the affray and running back to the shopping centre. At trial Cameron Ferguson pleaded guilty to murder and grievous bodily harm. Alex Henry and Janhelle Grant-Murray were both found guilty by a majority verdict of 11–1. It was their presence at the scene of the spontaneous 47-second affray which was held to amount to encouragement of the stabbing. They both received a life sentence with a minimum prison term of 19 years. On 25 February 2015, an appeal to the Court of Appeal by two convicted murderers was successful. A young man, Jonathan Fitchett, had been killed at a retail park after an altercation with Childs, who was joined by his friend Price. Although both defendants had punched the victim, an expert medical witness said that just a single punch was fatal, and it was unknown who threw the fatal punch. The Liverpool Crown Court had convicted both of murder using the device of common purpose. The Appeal Court found that there had been no intent to cause really serious injury, and that there was no evidence of "common purpose". The first defendant's conviction was reduced to manslaughter, and the second was reduced to
affray In many legal jurisdictions related to English common law, affray is a public order offence consisting of the fighting of one or more persons in a public place to the terror (in french: à l'effroi) of ordinary people. Depending on their act ...
. The Court said that for common purpose/joint enterprise to arise, there must be satisfactory evidence of a joint plan. (The absence of precise ''
actus reus (), sometimes called the external element or the objective element of a crime, is the Law Latin term for the "guilty act" which, when proved beyond a reasonable doubt in combination with the ("guilty mind"), produces criminal liability in th ...
'' was glossed over.)


See also

*
Felony murder rule The rule of felony murder is a legal doctrine in some common law jurisdictions that broadens the crime of murder: when someone is killed (regardless of intent to kill) in the commission of a dangerous or enumerated crime (called a felony in s ...
*
Joint criminal enterprise Joint criminal enterprise (JCE) is a legal doctrine used during war crimes tribunals to allow the prosecution of members of a group for the actions of the group. This doctrine considers each member of an organized group individually responsibl ...
*
Art and part Art and part is a term used in Scots law to denote the aiding or abetting in the perpetration of a crime, or being an accessory before or at the perpetration of the crime. There is no such offence recognised in Scotland, as that of being an acce ...
, a similar principle under
Scots Law Scots law () is the legal system of Scotland. It is a hybrid or mixed legal system containing civil law and common law elements, that traces its roots to a number of different historical sources. Together with English law and Northern Ireland l ...
* ''
R v Betts and Ridley ''R v Betts and Ridley'' (1930) 22 Cr App R 148 is a 1930 landmark case in English criminal law that established and confirmed that to be convicted of a crime under the doctrine of common purpose, it was not necessary for the accessory to be p ...
''


References

*Baker, Dennis J. ''Glanville Williams, Textbook of Criminal Law''. Sweet & Maxwell, London University Press, London. Chapter 14, p. 475 (2012) ; Dennis J. Baker, "Liability for Encouraging One's Own Murder, Victims, and Other Exempt Parties' (2012) 23(3) ''King's Law Journal'' 257–285. *Wilson, William. ''Criminal Law Theory and Doctrine'', Pearson, London. (2010). *

' *

' *''Joint Enterprise Cases'' – detailed accounts of high-profile cases where the doctrine of common purpose has been applied. {{DEFAULTSORT:Common Purpose Criminal law