LAW

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KembaraXtra- Case Law- Ryan (1996)

​Burglary & Entry

Facts of the Case:
  • Defendant (D): Found stuck in a downstairs window of an occupied house in the early morning.
  • D's Position: Head and arm inside the window; the rest of his body outside. Window resting on his neck, trapping him.
  • D's Claim: Trying to retrieve his baseball bat, which a friend had put through the window.
  • Conviction: Initially convicted of burglary.
  • Appeal: Appealed on the basis that his action did not constitute an "entry" under s 9 of the Theft Act 1968.
II. Legal Issue:
  • Did D's partial intrusion into the house through the window constitute an "entry" for the purposes of burglary under s 9 of the Theft Act 1968, even though he was physically trapped?
III. Held (Court's Decision):
  • Entry Established: It was possible to enter a building under s 9, even when only part of the body was inside, citing Brown as precedent.
  • Irrelevant Incapacity: It was irrelevant that D was incapable of stealing anything because he was trapped. The act of entering with the intent to commit theft (or other relevant offense) is sufficient.
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