joint enterprise to murder 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 if they had the necessary mens rea. 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 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 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, 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 [1999] 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