1. Griew E. , The Theft Acts 1968 and 1978, 4th ed. (1982), pp. 57–58
2. Woolven (1983) 77 Cr.App.R. 231. The trial judge directed the jury thus, “If… your final conclusion is that notwithstanding what the accused did he may not have regarded it as dishonest, that is an answer to this charge” (p. 236). This is somewhat ambiguous on the point, but, if anything, suggests that a “don't know” suffices for an acquittal. The Court of Appeal approved that direction, but said that it had brought home to the jury that they must acquit if “they thought he might have regarded his actions as honest” (p. 236), which, if anything, suggests that a “don't know” does not suffice. In this article I shall not discuss one implication of Woolven, namely that the Court of Appeal may, in time, be bound to infer from its own decision in Ghosh that the test in that case itself swallows up all of the partial definition of “dishonestly” which is provided by s.2 of the 1968 Act.
3. Smith J. C. , “Commentary on R. v. Ghosh” [1982] Crim.L.R. 608.
4. Elliott D. W. , “Dishonesty in Theft: A Dispensable Concept” [1982] Crim.L.R. 395.
5. Williams G. , “The Standard of Honesty” (1983) 133 N.L.J. 636.