What is the ratio in R v Campbell?

Acts of approaching premises with intent and tools to commit robbery, without entering or confronting victims, remain merely preparatory and insufficient for attempt liability.

What did the court decide in R v Campbell?

The Court of Appeal quashed the conviction for attempted robbery, finding the defendant's acts were merely preparatory.

Why is R v Campbell important for criminal attempts?

It demonstrates the high threshold for attempt liability and shows how the Gullefer test operates in practice, requiring actual commencement of the substantive offence.

What is the ratio in R v Campbell?

Acts of approaching premises with intent and tools to commit robbery, without entering or confronting victims, remain merely preparatory and insufficient for attempt liability.

What did the court decide in R v Campbell?

The Court of Appeal quashed the conviction for attempted robbery, finding the defendant's acts were merely preparatory.

Why is R v Campbell important for criminal attempts?

It demonstrates the high threshold for attempt liability and shows how the Gullefer test operates in practice, requiring actual commencement of the substantive offence.

Criminal1 min read

R v Campbell (Attempts)

(1991) 93 Cr App R 350Court of Appeal1991

Cite this case in OSCOLA →All Criminal cases →

“Approaching premises with intent insufficient for attempted robbery without entry”

Facts

Campbell planned to rob a post office. He was arrested outside the post office carrying an imitation firearm and a threatening note, having approached within a yard of the door but not entered. He was convicted of attempted robbery.

Issues

Whether approaching premises with the tools necessary to commit robbery, but without entering or confronting the victim, constituted acts more than merely preparatory to robbery.

Held

The Court of Appeal quashed the conviction. The acts were merely preparatory as Campbell had not entered the post office or confronted anyone.

Significance

This case demonstrates the strict application of the Gullefer test and shows how close to completion a defendant can be while still being in the preparatory stage. It's crucial for understanding the high threshold required for attempt liability and is frequently cited in criminal law education.

Read the full brief — free

You're reading the free summary of R v Campbell (Attempts). Create a free account to unlock the full reasoning, the cited authorities and the verbatim judgment — plus structured briefs for 412,000+ UK judgments.

Create free account Already have one? Sign in

No card required. Free forever.

OSCOLA Citation

R v Campbell (Attempts) (1991) 93 Cr App R 350 (CA)

Criminal LawCriminal AttemptsRobberyInchoate Offences

Read the full judgment elsewhere

Multiple official and mirror sources — pick whichever loads cleanly on your network.

LLBGDL

More Criminal cases

R v Reece Martin Kelly

[2026] EWCA Crim 268

R v Richard Alexander Welsh

[2026] EWCA Crim 466

R v Robert Michael Thomas

[2026] EWCA Crim 305

This case is reproduced verbatim from the public judgment published by The National Archives under the UK Government's Open Government Licence v3.0. If you appear in this case and believe it should not be published — for example because your conviction was quashed on appeal, you have statutory anonymity, or for other privacy reasons — request removal here.