Lawrence v Commissioner of Police of the Metropolis [1972]

Lawrence v Commissioner of Police of the Metropolis [1972]

Lawrence v Commissioner of Police of the Metropolis [1972] AC 262, also referred to as R v Lawrence [1972] is a significant English criminal law case that shaped the interpretation of property appropriation under the Theft Act 1968. This case, heard in the House of Lords, addressed the intriguing question of whether property appropriation could be considered even when the owner gave consent.

At London Victoria railway station, an Italian student entered a taxi and handed the driver a piece of paper with his destination. The driver, foreseeing a long and expensive journey, took £6 from the student's wallet to ostensibly cover the fare. Unbeknownst to the student, the correct fare was significantly less. The taxi driver was charged under section 1 of the Theft Act 1968.

The following elements are required for an offence under Section 1 of the Theft Act 1968:
  1. Dishonesty
  2. Appropriation
  3. Property
  4. Belonging to another
  5. Intention of permanently depriving the other of it

The House of Lords upheld the Court of Appeal's judgment, affirming the conviction. The critical interpretation was whether an appropriation could occur even with the consent of the owner. Viscount Dilhorne highlighted that the omission of without the consent of the owner in the statute was deliberate, relieving the prosecution of establishing a lack of consent. Dilhorne emphasised that an appropriation could be consented to, and the issue of dishonesty should be assessed separately.

The House of Lords ruled that an appropriation of property could occur even with the consent of the owner. The drafter's intentional omission of "without the consent of the owner" relieved the prosecution of proving a lack of consent. An appropriation could be deemed dishonest if the accused believed the owner had consented to the appropriation but acted dishonestly in the circumstances. Belief or absence of belief in the owner's consent is relevant to the issue of dishonesty, not to the question of whether an appropriation occurred.

This case clarified that, under the Theft Act 1968, an appropriation can happen with the owner's consent. The focus shifted to the accused's dishonesty, establishing a distinct criterion for theft offences. The intentional legislative choice reflected a departure from requiring the prosecution to prove the absence of consent in theft cases.
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