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Date Updated: January 2012

Title: Theft

Offence: Handling

Legislation: S22 Theft Act 1968

Mode of Trial: Either Way

Statutory Limitations & Maximum Penalty: 14 years
Grave Crime

Culpability & Harm

  • the closeness of the handler to the original offence: geographical (present or near the primary offence) or temporal (i.e. instigated or encouraged the primary offence or soon after provided a safe haven or route of disposal)
  • a high level of seriousness of the original offence
  • high value of the goods to the loser (including sentimental value)
  • the fact that the goods handled were the proceeds of a domestic burglary
  • a high degree of sophistication in the commission or organisation of the handling
  • a high level of profit made, or expected to be made, by the handler
  • the fact that the handler provided a regular outlet for stolen goods
  • threats of violence or abuse of power by the handler over others (eg an adult commissioning children to steal, or a drug dealer pressurising addicts to steal in order to pay for their habit)
  • commission of the offence while the offender was on bail.

Aggravating & Mitigating Factors

  • Sophistication - professional hallmarks
  • Destination of goods - resale
  • Origins of goods - home, school or hospital
  • Impact on victim
  • Level of profit
  • Role of offender

Relevant Sentencing Guidelines (If Any)

R v Webbe and Others [2002] 1 Cr. App. R. (S) 22 (at 82): [2001] EWCA Crim. 1217

  • Property <£1K for own use. Fine or Community Order.
  • Property <£1K for resale or £1K for personal use or presence of aggravating feature. Community Order - 12 week.
  • Sophisticated offence or two or more aggravating features. 6 weeks - 1 year.
  • Property <£100K or offence committed in the context of a business, or the offender is acting as an organiser or distributor of the proceeds of crime or whether the offender has made himself available to other criminals as willing to handle the proceeds of thefts or burglaries.1 - 4 years
  • Property >£100K or the offence is highly organised and bears the hallmarks of a professional commercial operation, a sentence of 4 years and upwards is likely to be appropriate, and it will be the higher where the source of the handled property is known by the handler to be a serious violent offence such as armed robbery. 4 -14 years.

Relevant Sentencing Case Law

Proceeds of Major Crime:

R v Patel [1984] 6 Cr. App. R. (S) 191
Convicted of handling stolen goods. He had received 660 cartons of cigarettes, worth £160,000, part of a larger consignment worth £1 million which had been stolen from a manufacturer's depot. Previous for drug smuggling. At the top end of the scale come the cases where the handler provides an outlet for the proceeds of very substantial thefts or robberies, where the advantages to the thief of having such an outlet are very great and where accordingly the receiver or handler is indirectly encouraging the thefts to take place, and where also the profits to the handler are likewise very great, as plainly they were going to be here had this criminal plan succeeded. 4 years.

R v Hutchings and Others [1993] 15 Cr. App. R. (S) 498
Convicted of handling stolen property. The defendants handled bags stolen in a £65K armed post office van robbery. The defendants did not commission the offence and were not professional receivers. 7 years.

R v Shearer and Lynch [1997] 1 Cr. App. R. (S) 159
Pleaded guilty and convicted of handling stolen goods. The defendants were convicted of receiving large sums of money which had been stolen in a robbery of a security vehicle. Professional criminals. 7 and 8 years.

R v Leitch and Others [1986] 8 Cr. App. R. (S) 290
Convicted or pleaded guilty to charges of theft, handling stolen goods, or conspiracy to handle stolen goods. The defendants were baggage handlers variously concerned in stealing blank traveller's cheques from mail bags at Heathrow Airport, and arranging for them to be encashed. The total loss was in excess of £1 million. Breach of trust in excess £100K carefully planned. 7 to 4 years.

R v Reader and Others [1988] 10 Cr. App. R. (S) 210
Convicted of conspiracy to handle stolen goods. The defendants were concerned in disposing of gold bullion worth £26 million from the Brink's Mat robbery. 14, 10 and 9 years.


R v Amlani and Smith [1995] 16 Cr. App. R. (S) 339
Convicted of handling stolen goods. The second defendant received a quantity of stolen mobile telephones; the first defendant assisted in making arrangements for their sale. Property of considerable value, and the defendants are mature men of business experience, but not professional handlers of stolen goods. Deterrence. 21 months.

AG's Reference No. 70 of 1999 (R. v Rance) [2000] 2 Cr. App. R. (S) 28
Convicted of conspiracy to handle stolen goods and conspiracy to steal, pleaded guilty to taking part in the management of a company whilst and undischarged bankrupt, and of conspiracy to handle stolen goods. Over a period of some months the offender received a substantial quantity of stolen computer equipment from a variety of sources, and sold the stolen equipment through his business. The offender agreed to buy a lorry load of computers worth about £250,000, which were to be stolen by one of his suppliers. 12 months increased 30 months. Tariff after trial 4 years.

Car ringing:

AG's Reference Nos 110 and 111 of 2001 (David Craven Dillon and Peter Charles Dunlop) [2002] 2 Cr. App. R. (S) 121 (at 546), [2002] EWCA Crim 886. Current Sentencing Practice B6-53A09
Pleaded guilty to conspiring to handle stolen cars and witness intimidation. The conspiracy was committed over a period of 15 months. The conspirators would go to car auctions sale rooms and the like making a note of the makes, models, registration numbers and colours of cars for sale and use these details to ring cars. 32 false details obtained. 89 cars ringed. Profit £200K. 18 and 15 months increased 4 years and 2 years 8 months.

R v Okoro (7 Oct 1997 unreported)
Convicted of handling. The defendant, a shipping agent, arranged containers to transport 6 cars worth £200K to Ghana. 4 years.

Handling proceeds of burglaries:

R v Love and Others [1999] 1 Cr. App. R. (S) 75
Two defendants were convicted of two counts of handling stolen goods; the third pleaded guilty. The defendants were concerned in handling valuable artistic property stolen in two burglaries. The defendants were contacted by an undercover police officer who posed as an agent for a potential purchaser of the property. No evidence that these were isolated offences. 3 years 9 months and 3 years 3 months.

R v Dixon [2002] 2 Cr. App. R. (S) 5 (at 18); [2001] EWCA Crim. 2507
Pleaded guilty to handling stolen goods. Police officers executing a search warrant found antiques to the value of £255,000 which had been stolen eight days earlier in a burglary of a dwelling while the occupiers of the house were attending a funeral. The defendant claimed that he was looking after the goods for another person whom he declined to name. The defendant was sentenced on the basis that he had dishonestly undertaken or assisted in the retention of the goods. Not professional handlers unaware of the value of the antiques. 18 months.

R v Chalcroft and Campbell [2002] 2 Cr. App. R. (S) 42 (at 172); [2001] EWCA Crim. 2931
Pleaded guilty to attempting to handle stolen goods. The defendants agreed to buy stolen goods from an undercover police officer. The defendant believed that he was speaking to the burglar, discussed what should be burgled and anticipated a large profit. 10 months and 8 months.

R v Gwyer [2002] 2 Cr. App. R. (S) 56 (at 246), [2002] EWCA Crim. 102
Convicted on nine counts of handling stolen property. The defendant and his co-defendant were involved in handling of antiques worth £16K stolen in the course of residential burglaries, having been in possession of the property shortly after the burglaries. Professional fences but substantial delay before trial. 4 years.


R v T and F [2001] Cr. App. R. (S) 294
The defendants (13 years) discussed and were present when a ladies bag was taken in a knife point robbery and shared the proceeds receiving £5. Bad records. 12 months DTO.

R v Webbe, M and D [2002] 1 Cr. App. R. (S) 82
The defendants M and D (14 - 17 years) were present when one's brother punched a woman and stole her handbag. One defendant received £5 the other admitted examining the contents. Poor records. 12 months DTO.

Ancillary Orders:

  • Restitution
  • Compensation
  • POCA

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