ROBBERY

Canada – Robbery is a serious, indictable offence under the Canadian CRIMINAL CODE (s302), punishable by life imprisonment. Basically robbery consists of 2 elements: the theft or extortion of property, and the use of a weapon, violence or threats of violence.

UK – Elements. Section 8(1) TA 1968 defines robbery as follows: “A person is guilty of robbery if the person steals, and immediately before or at the time of doing so, and in order to do so, they use force on any person or puts or seeks to put any person in fear of being then and there subjected to force.”

USA – The FBI’s Uniform Crime Reporting (UCR) Program defines robbery as the taking or attempting to take anything of value from the care, custody, or control of a person or persons by force or threat of force or violence and/or by putting the victim in fear.

THEFT

Canada – What is Theft in Canada? Section 322 of the Criminal Code states that it is illegal to “fraudulently and without colour of right The honest belief that an act is justifiable” take someone’s property. It doesn’t matter if your intention is to take possession of an item only temporarily from its rightful owner.

UK – A person is guilty of theft if he dishonestly appropriates property belonging to another with the intention of permanently depriving the other of it; and “thief” and “steal” shall be construed accordingly.

USA – The FBI’s Uniform Crime Reporting (UCR) Program defines larceny-theft as the unlawful taking, carrying, leading, or riding away of property from the possession or constructive possession of another. Examples are thefts of bicycles, thefts of motor vehicle parts and accessories, shoplifting, pocket-picking, or the stealing of any property or article that is not taken by force and violence or by fraud. Attempted larcenies are included in offense totals. Embezzlement, confidence games, forgery, check fraud, etc., are excluded.