Where an offender is convicted of manslaughter arising from a joint criminal enterprise to commit robbery, the planning of the robbery does not make the manslaughter 'part of a planned or organised criminal activity' under s 21A(2)(n), because the statutory provision requires a more extensive criminal undertaking and the species of manslaughter did not involve planning of a killing. Similarly, where being in company is an integral component of the offender's liability for manslaughter (as in extended joint criminal enterprise), it cannot also be treated as a statutory aggravating factor under s 21A(2)(e).
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