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. 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 was glossed over.) See also Felony murder rule Joint criminal enterprise Art and part, a similar principle under Scots Law R v Betts and Ridley 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. Criminal law