A joint criminal enterprise to rob does not come to an end until the robbers have made their escape from the scene of the crime, by analogy with bank robbery cases. Where co-offenders each carry knives and one uses his knife offensively to resist arrest, the inference that the other contemplated the possible use of a knife to stab someone attempting to effect an arrest is strongly supported. The Court left open the question whether, for extended joint criminal enterprise manslaughter, the contemplated act (brandishing a knife) and the actual act (stabbing) must be of the same type or kind.
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