## 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.


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