Editing Robbery (section)

===== "Steals" =====
This requires evidence to show a [[theft]] as set out in section 1(1) of the Theft Act 1968. In ''R v Robinson''<ref>R v Robinson [1977] Crim LR 173, CA</ref> the defendant threatened the victim with a knife in order to recover money which he was actually owed. His conviction for robbery was quashed on the basis that Robinson had an honest, although unreasonable, belief (under Section 2(1)(a) of the Act) in his legal right to the money. See also ''R v Skivington'' [1968] 1 QB 166, [1967] 2 WLR 655, 131 JP 265, 111 SJ 72, [1967] 1 All ER 483, 51 [[Cr App R]] 167, CA.

In ''R v Hale'' (1978)<ref>''R v Hale'' (1978) 68 Cr App R 415, [1979] Crim LR 596, [[Court of Appeal of England and Wales|CA]]</ref> the application of force and the stealing took place in many different locations, and it was not possible to establish the timing; it was held that the appropriation necessary to prove theft was a continuing act, and the jury could correctly convict of robbery. This approach was followed in ''R v Lockley'' (1995)<ref>Crim LR 656</ref> when the force was applied to a shopkeeper after property had been taken. It was argued that the theft should be regarded as complete by this time, and ''R v Gomez'' (1993),<ref>[1993] AC 442, House of Lords</ref> should apply; the court disagreed, preferring to follow ''R v Hale''.