​KembaraXtra - Case Law - Lloyd (1985)
Theft Act & Intention to Permanently Deprive
I. Case Summary:
Defendant (D): Projectionist at a cinema.
Action: Secretly borrowed films during the day, lent them to friends for illegal copying, then returned them before showing time.
State of Films: Undamaged and ready for public viewing.
Original Conviction: Theft.
II. Legal Issue:
Whether borrowing property constitutes an intention to permanently deprive the owner under Section 6(1) of the Theft Act 1968.
III. Court Ruling (Held):
Borrowing only equates to intending to permanently deprive if the property is returned in a significantly altered state, rendering it practically valueless.
Key Phrase: "changed state that it had lost all its practical value."
IV. Application to the Case:
The films retained their practical value (could still be shown).
Therefore, D did not intend to permanently deprive the cinema.
Outcome: D's conviction was likely overturned (not explicitly stated, but implied).
V. Key Takeaways:
Section 6(1) Interpretation:  Mere temporary deprivation, even if unauthorized, is insufficient for theft unless the property's value is significantly diminished upon return.
Focus on 'Practical Value': The condition of the property after the unauthorized use is crucial.  Does it still serve its original purpose?