## Facts

- The defendants in R v Morris switched price labels on supermarket items to pay less for more expensive goods.
- Customers were permitted by the shop to handle and select items before purchase.
- The defendants’ actions raised the question whether switching price labels constituted "appropriation" as defined under the Theft Act 1968.
- The case proceeded to the House of Lords for determination on the scope of "appropriation."

## Issues

1. Whether the act of switching price labels on goods amounts to an appropriation of the owner’s rights for the purposes of the Theft Act 1968.
2. Whether appropriation under the Theft Act requires adverse interference with the owner’s rights.
3. The extent to which assumption of any, rather than all, of the owner’s rights constitutes appropriation.

## Decision

- The House of Lords held that the act of switching price labels was an appropriation of the owner’s rights under the Theft Act 1968.
- It was determined that assuming any of the rights of the owner—including the right to determine the price—satisfied the requirement of appropriation.
- The Court clarified that appropriation does not require taking all of the owner's rights; the assumption of any one right is sufficient.
- The judgment noted that appropriation can occur even before actual removal of goods from a store.
- The requirement for "adverse interference" with ownership rights, as interpreted in Morris, was later overruled by R v Gomez [1993] AC 442.

## Legal Principles

- Appropriation under the Theft Act 1968 consists of the assumption of any of the rights of an owner, not necessarily all.
- Dishonest assumption of an owner’s right, such as setting the price, can constitute the actus reus of theft.
- The concept of appropriation is not dependent on the absence of the owner’s consent when dishonesty is present (as clarified in later cases).
- Legal developments, particularly R v Gomez, removed the necessity for “adverse interference” in appropriation.
- The offense of theft requires dishonest appropriation of property belonging to another with the intention to permanently deprive.

## Conclusion

R v Morris clarified that appropriation under the Theft Act involves assuming any of the owner’s rights, such as the right to set the price of goods. While significant in shaping legal interpretation of appropriation, its requirement for adverse interference was later rejected by the House of Lords in R v Gomez, which further broadened liability under the theft provisions.


R v Morris [1984] AC 320 (HL)