I. Introduction
In the recent past, hardly another topic in international criminal law has divided the minds of academics and practitioners alike as heavily as the dogmatic figure of Joint Criminal Enterprise (JCE)1 created for the purpose of imposing individual criminal liability in situations of mass atrocities and collective criminal activity. This holds true especially in regard to the third category of the doctrine, the so-called extended JCE (JCE III). It is without calling for speculation to state that the division of minds seemingly follows the distinction between learned practitioners of criminal law and academics from public international law. Strictness v. flexibility! Self-restraint v. wishful thinking? Conservatism v. "Grotian Moments"2?
