Actions of a principal party causing the death of a victim were outside the scope of joint enterprise where those actions were fundamentally different to what was contemplated by a secondary party. In the instant case although the actions of the principal were contemplated by the offender, the judge's direction failed to focus the jury's mind on the question of whether the offender had withdrawn from the joint venture at the time when the fatal blows were struck, and therefore the offender's conviction for manslaughter was unsafe.

[2005] EWCA Crim 1981

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