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R v Morris – 1983

April 02, 2024
Micheal James

Jurisdiction / Tag(s): UK Law

Introduction to R v Morris – 1983

The 1983 case of R v Morris is a leading English judgment that significantly shaped the legal understanding of “theft” under the Theft Act 1968. This case study delves into the details of the case, its legal significance, and its lasting impact.


Mr. Morris, the defendant, entered a supermarket and deliberately switched the price labels on several items. He then proceeded through checkout, paying the lower prices reflected on the swapped labels. This seemingly simple act triggered a legal debate, leading to Mr. Morris being charged with theft under Section 1 of the Theft Act 1968.

Legal Issue(s)

The central legal question in R v Morris revolved around the definition of “appropriation” within the context of theft. The Theft Act 1968 defines theft as the dishonest appropriation of property belonging to another with the intention of permanently depriving them. The crux of the issue was whether Mr. Morris’s act of switching labels before payment constituted theft, or if his actions amounted to mere deception at the checkout.

Relevant Law

Section 1 of the Theft Act 1968 provides the legal framework for theft. It defines theft as a person who “dishonestly appropriates property belonging to another with the intention of permanently depriving them of it; and the taking or carrying away of it is necessary to the act of appropriation.”

Reasoning and Holding

The defense in R v Morris argued that Mr. Morris hadn’t truly “appropriated” the goods until he paid the lower, swapped-label price at the checkout. They contended that before that point, he was simply holding the items like any other customer.

The House of Lords, the highest court in the United Kingdom, disagreed. They found Mr. Morris guilty of theft. Their reasoning focused on the concept of “appropriation” not requiring a completed transfer of ownership, but rather the dishonest act of treating the property as one’s own. By switching the labels with the intention of paying a lesser price, Mr. Morris had effectively dealt with the goods as if they were his own, fulfilling the elements of appropriation under the Theft Act.


The R v Morris decision stands as a landmark case in English law. It significantly clarified the law on theft and the concept of appropriation. The case established that theft can occur even before payment is completed, as long as there’s a dishonest intent to deprive the owner of their rightful selling price. This decision has had a lasting impact on subsequent cases dealing with theft by deception and fraudulent misrepresentation.

It’s important to note a related case decided alongside R v Morris – Anderton v Burnside. In Anderton, the defendant was acquitted of theft after taking a coat without paying, but then attempting to return it. The distinction between the two cases lies in the intention of the defendant. In Anderton, the court found there was no intent to permanently deprive the owner of the coat. In contrast, Mr. Morris in the R v Morris case clearly intended to pay a lower price than intended by the shopkeeper.


The R v Morris case serves as a crucial precedent in English law. It broadened the definition of theft to encompass situations where dishonest manipulation occurs before a traditional sale is complete. The case highlights the importance of intention and dishonesty in determining theft, rather than solely the act of payment.

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