Your Cart

R v Hale [1979]

R v Hale [1979] 68 Cr App R 415, [1979] Crim LR 596 addressed the question of whether appropriation ceases once property is seized and emphasised that appropriation is a continuous act.


The defendants broke into the victim's house, covering her mouth to prevent her from screaming, going upstairs to take a jewellery box, and tying her up before leaving the house. The defendants appealed their conviction for robbery, arguing that under Section 8(1) of the Theft Act 1968, the use of force had to be immediately before or during appropriation, and that appropriation completed once the jewellery box was seized.


The Court of Appeal dismissed the appeal, rejecting the contention that theft had ceased by the time the victim was tied up. Eveleigh LJ, in delivering the judgment, stated that the act of appropriation does not suddenly cease. Instead, it is considered a continuous act. The court emphasised that it is a matter for the jury to decide whether the act of appropriation has concluded.


This decision underscored the idea that appropriation is not a single, isolated act but a continuous process, and the use of force during this process can be considered in determining the offence of robbery.


Check out our exam-focused Criminal Law notes now.


Subscribe to UOL Case Bank for more exclusive content and case summaries.

Trusted by thousands of law students worldwide

Where are our students from?

Yale University

Council of Europe

Baker Mckenzie 

University of Chicago

Columbia University

New York University

University of Michigan 

INSEAD

University College London (UCL)

London School of Economics (LSE)

King’s College London (KCL)

University of London

University of Manchester

University of Zurich

University of York

Brandeis University

University of Exeter

University of Sheffield

Boston University

University of Washington

University of Leeds

University of Law

Royal Holloway, University of London 

Birkbeck, University of London

SOAS, University of London

University of Kent

University of Hull

Queen’s University Belfast

Toronto Metropolitan University

Hong Kong University of Science and Technology

Your perfect companion for open-book and closed-book exams

Diagrams and Charts

Our carefully designed diagrams and charts will guide you through complex legal issues.

Clear and Succinct Definitions

Key concepts are concisely defined to help you understand legal topics quickly.

Statutory Provisions

Statutory provisions are provided side by side with legal concepts to help you swiftly locate the relevant legislation.

Case Summaries

We have summarised important cases for you so that you don't need to read long and boring cases.

Rules and Exceptions

Rules and exceptions are clearly listed so that you know when a rule applies and when it doesn't.

Terminology

Legal terms and key concepts are explained at the beginning of each chapter to help you learn efficiently.

Case Law

Case law is provided side by side with legal concepts so that you know how legal principles and precedents were established.

Law Essay Guide

You will learn essential law exam skills and essay writing techniques that are not taught in class.

Problem Question Guide

We will show you how to answer problem questions step by step to achieve first-class results.

Structured Explanations

Complex legal concepts are broken down into concise and digestible bullet point explanations.

Legal Research

You will learn legal research techniques with our study guide and become a proficient legal researcher.

Exam-focused

All essential concepts, principles, and case law are included so that you can answer exam questions quickly.