A person is guilty of robbery if he steals and
immediately before or at the time of doing so,
uses force on any person, or puts or seeks to put
any person in fear of being, then and there,
subjected to force.
Theft must be proved
first before the
defendant can be
convicted of robbery.
The defendant's conviction was quashed as he hadn't
fulfilled the theft part of the mens rea, which required
the dishonest appropriation of the property; the
defendant honestly believed he was owed the movie.
The defendant doesn't have
to successfully get away with
the property for it to be
classed as robbery
Corcoran v Anderton 1980
The defendants' dropped the victim's handbag when
she screamed. They were still convicted of burglary
as appropriation didn't require the defendant's to
have complete control over the bag.
Jury decides whether the
defendant's actions amounted
Force can be minimal and
is what turns theft into
Force doesn't have to be
physical contact between
the defendant and the
Dawson and James 1976
The defendants' robbery convictions were upheld,
after they nudged the victim to retrieve a wallet, as
the COA stated that 'force' was an ordinary English
word which is to be determined by the jury.
This decision was followed in the case of: Clouden
The defendant was convicted after
'wrenching' the victim's shopping basket out
of her hands. The courts said force used on
the basket was effective as using force on
Force is treated as a continuing act as well
as the force having to occur immediately
before or at the time of the offence.
His conviction was upheld
as force is a continuing act
and the force was used to
complete the robbery.
If it happens at different times and the force isn't used
to steal, then it would be regarded as two separate
The defendant used force on the
shopkeeper to escape with the can
of beer he had stolen. His conviction
was upheld as force is a continuing
act and he used it to complete his
Fear of force
This includes threatening words or
Defendant convicted of robbery as he sought to put the victim in
fear of being subjected to violence. The defendant used his
hand to imitate the shape of a gun in order to make the victim
give up her money and jewellery.
It also includes situations where the
victim is unaware of the threat of force,
i.e. if the defendant are approached
from behind or if the victim is
Robbery can still be committed if the victim wasn't frightened of
B and R v DPP
The defendants' convictions were upheld as
they sought to put him in fear, even though the
victim didn't feel threatened.
Same as the mens rea for theft
s2 Theft Act 1968
Have the intention to permanently deprive the other of the
s6 Theft Act 1968
Have the intention in relation to the use of force