“Robbery is continuing act - force can occur during ongoing theft”
Hale and another defendant entered a house and stole a jewellery box. As they were leaving, one defendant tied up the householder to prevent her from calling the police. They argued that the theft was complete before the force was used.
Whether robbery requires force or the threat of force to occur at the precise moment of appropriation, or whether it can occur during a continuing act of theft.
The Court of Appeal upheld the robbery convictions. The court ruled that appropriation is a continuing act and force used during the ongoing theft satisfied the requirements for robbery.
This case is fundamental to understanding robbery law, establishing that the timing requirements are more flexible than might initially appear. It ensures that defendants cannot escape robbery charges by using force slightly after the initial taking.
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OSCOLA Citation
R v Hale (1978) 68 Cr App R 415 (CA)
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