Editing Robbery (section)

===== Actual or threatened force against a person =====
The threat or use of force must take place immediately before or at the time of the [[theft]]. Force used after the theft is complete will not turn the theft into a robbery.

The words "or immediately after" that appeared in section 23(1)(b) of the [[Larceny Act 1916]] were deliberately omitted from section 8(1).<ref>The [[Criminal Law Revision Committee]]. Eighth Report. Theft and Related Offences. 1966. Cmnd 2977. Paragraph 65.</ref>

The book ''[[Archbold Criminal Pleading, Evidence and Practice|Archbold]]'' said that the facts in ''R v Harman'',<ref>''R v Harman'' (1620) 1 [[Historia Placitorum Coronæ|Hale]] [https://books.google.com/books?id=2KoDAAAAQAAJ&pg=PA534 534] {{Webarchive|url=https://web.archive.org/web/20160617124325/https://books.google.com/books?id=2KoDAAAAQAAJ&pg=PA534 |date=2016-06-17 }}, (1620) 2 Rolle 154, (1620) 81 [[English Reports|ER]] [http://www.commonlii.org/uk/cases/EngR/1676/218.pdf 721] {{Webarchive|url=https://web.archive.org/web/20131209024028/http://www.commonlii.org/uk/cases/EngR/1676/218.pdf |date=2013-12-09 }}</ref> which did not amount to robbery in 1620, would not amount to robbery now.<ref>''[[Archbold Criminal Pleading, Evidence and Practice]]'', 1999, para. 21-99 at p. 1772</ref>

It was held in ''R v Dawson and James'' (1978)<ref>''R v Dawson and James'' (1978) 68 Cr App R 170, CA</ref> that "force" is an ordinary English word and its meaning should be left to the jury. This approach was confirmed in  ''R v Clouden'' (1985)<ref>''R v Clouden'', unreported (C.A. No. 3897, 4 February 1985). For details see Griew, Edward. ''The Theft Acts 1968 and 1978''. Fifth Edition. Sweet and Maxwell. 1986. Paragraphs 3-04 and 3-05 at page 80.</ref> and ''Corcoran v Anderton'' (1980),<ref>''Corcoran v Anderton'' (1980) 71 Cr App R 104, [1980] Crim LR 385, [[Divisional Court (England and Wales)|DC]]</ref> both handbag-snatching cases. Stealing may involve a young child who is not aware that taking other persons' property is not in order.