Lawrence v Metropolitan Police Commissioner [1972] AC 626 (HL)

Facts

  • An Italian student unfamiliar with British currency arrived at London Victoria Station and engaged a taxi driven by Mr. Lawrence.
  • The student handed his wallet to Lawrence and indicated his destination, expecting Lawrence to take the correct fare.
  • Lawrence took significantly more money from the wallet than the required fare.
  • The student appeared to approve the taking of money, but his approval was influenced by Lawrence's deception.

Issues

  1. Whether the approval or consent given by the student, obtained through deceit, constituted valid consent for the purposes of property transfer in theft.
  2. Whether a dishonest taking of property, even with the owner's apparent agreement, amounts to theft if that agreement is secured by deception.

Decision

  • The House of Lords convicted Lawrence of theft, holding that consent obtained through deception is legally ineffective.
  • The court determined that the supposed approval given by the student did not constitute valid consent due to the confusion caused by Lawrence's dishonest conduct.
  • It was established that a dishonest transfer of property, even where superficial consent is present, remains theft if the consent results from deceit.

Legal Principles

  • For theft, assuming any rights of the owner over property can amount to an unlawful transfer if the consent is tainted by dishonesty.
  • Consent secured by deceit is not genuine and therefore does not preclude liability for theft.
  • Later cases, such as R v Morris [1984] AC 320 and R v Gomez [1993] AC 442, extended and affirmed that even the assumption of single rights, and any deceit invalidating consent, suffice for theft.
  • The principle applies broadly, including scenarios of online fraud, false advertising, or Ponzi schemes, where any approval of property transfer induced by falsehood is legally ineffective.

Conclusion

The decision in Lawrence v Metropolitan Police Commissioner established that consent to property transfer obtained through deception does not negate the dishonest taking; such transfers are theft, setting a precedent for addressing manipulated consent in theft law that continues to influence cases involving fraud and deceit.

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