## Facts

- Hall, a travel agent, accepted deposits from customers for flights.
- These deposits were placed into Hall’s general business account rather than kept in a separate account.
- When the business failed, customers lost their deposits.
- Hall was charged with theft of these customer deposits.

## Issues

1. Whether money received for a specific purpose is held by the recipient on trust for the payer.
2. Whether Hall’s actions in mixing customer deposits with general business funds amounted to theft under the Theft Act 1968.
3. Whether an intention or plan to keep funds separate is required to establish a trust over the money received.

## Decision

- The Court of Appeal held that the essential issue was whether Hall intended to keep the deposits separate for the designated purpose.
- There was no evidence that Hall intended to segregate the funds or create a trust.
- As a result, no trust existed; the deposits became Hall’s business assets.
- The conviction for theft was overturned.

## Legal Principles

- Money received for a specific purpose does not automatically constitute a trust; a clear plan or intention to keep the funds separate is required.
- The recipient’s intent regarding the funds can be explicitly stated or inferred from conduct but must be supported by evidence.
- In the absence of such intention, the payer’s funds become part of the general assets of the recipient and are not protected by a trust.
- The case distinguishes itself from situations like Davidge v Bunnett, where a trust arose due to a clear duty to apply the money only for a particular use.

## Conclusion

R v Hall clarified that accepting money for a specific purpose does not, by itself, create a trust unless there is evidence of intent to keep the funds separate; lacking such intent, the money forms part of the recipient’s general assets, and liability for theft does not arise under these circumstances.


R v Hall [1973] QB 496