R v Lloyd [1985] QB 829 (CA)

Facts

  • The defendants, employed as cinema projectionists, removed film reels from their workplace without permission.
  • The reels were taken, copied, and later returned to the cinema before their absence was discovered.
  • The prosecution argued this constituted theft, as it deprived the cinema owners of the exclusive value of the films.

Issues

  1. Whether temporary removal and copying of property, with subsequent return of the original item, constitutes theft under the Theft Act 1968.
  2. Whether the defendants' actions amounted to an intent to permanently deprive the owners of their property, given the property’s full return.

Decision

  • The Court of Appeal quashed the theft convictions.
  • Lord Lane CJ established that short-term use is not theft unless the defendant’s actions are equivalent to keeping the property permanently.
  • The decisive test is whether the defendant removed “all the function, quality, or main value” of the property.
  • Returning the original film reels, even after unauthorized copying, was insufficient for theft as the owners’ control over the physical items was not lost.

Legal Principles

  • The definition of theft under the Theft Act 1968 requires intent to permanently deprive the owner of property.
  • “Function, quality, or main value” encompasses both physical characteristics and the owner’s legal rights or interests in the property.
  • Section 6(1) of the Theft Act 1968 extends intent to permanently deprive to cases where property is treated as one’s own, disregarding the owner’s rights, particularly where property is sold, pledged, or otherwise disposed of while intending recovery later.
  • Returning property in an unchanged state, with its main value intact, does not necessarily demonstrate intent to permanently deprive, but actions eliminating core value or function may qualify as theft.

Conclusion

R v Lloyd clarified that temporary deprivation is not theft unless the defendant’s actions remove the essential value, function, or quality of the property; intent to permanently deprive must be evidenced by such removal, as mere unauthorized use with restoration of the item does not suffice under the Theft Act 1968.

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