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R v Lockley [1995] Crim LR 656

The defendant had been caught shop lifting by a security guard. He used force on the security guard in order to escape. He was convicted of robbery and appealed contending that the case of Gomez had impliedly overruled Hale on the point relating to the appropriation being a continuing act.

Held:

Appeal dismissed. Hale was still good law and an appropriation is a continuing act. Force used in order to escape is thus treated as force used in order to steal and his conviction was upheld.
 
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