Corcoran v Anderton
Theft is complete for the purposes of robbery as soon as the defendant assumes the owner's rights, even if he does not get away with the property.
Facts
Two youths attacked a woman in the street. One of them hit her in the back and tried to pull her handbag from her. The bag fell to the ground, and the youths ran away without it. One of them was convicted of robbery, and argued that there was no theft, because they had not taken the bag away.
Legal principle
The Divisional Court upheld the conviction. Watkins LJ said that an appropriation took place when the youth tugged at the bag, because by doing so he assumed the rights of the owner, and it did not matter that he did not succeed in removing the bag from the scene. The theft was complete, and the force used at the time made it a robbery. The case shows how the wide definition of appropriation from R v Morris affects robbery.
Related cases on theft, robbery, burglary and fraud
- Attorney General's Reference (No 1 of 1983) [1985] QB 182
- Ivey v Genting Casinos (UK) Ltd [2017] UKSC 67, [2018] AC 391
- Lawrence v Metropolitan Police Commissioner [1972] AC 626
- Oxford v Moss (1979) 68 Cr App R 183
- R v Barton and Booth [2020] EWCA Crim 575, [2021] QB 685
- R v Collins [1973] QB 100
- R v Ghosh [1982] QB 1053
- R v Gomez [1993] AC 442
Studying criminal law? Our tutors help you understand and apply cases like this in essays, problem questions and exams. Request a quote or browse our law notes.
This summary is for study and revision and is not legal advice. Although our case summaries are checked for accuracy, we do not guarantee that they are free from errors or omissions. Always read the full judgment for the court's reasoning.
