R v Watson (George) – Case Summary

R v Watson (George)

Court of Appeal

Citations: [1916] 2 KB 385.


The defendant met two men who told him that they had some stolen jewellery to sell. The defendant went a jeweller with the two men and negotiated for the sale of the jewellery, but never came into possession of the stolen goods. The jewellery refused to buy the goods. The defendant was convicted of receiving stolen goods, on the grounds that he ‘aided and abetted‘ the two men. He appealed his conviction on the grounds that he never ‘received’ the goods.

  1. When does a defendant ‘receive’ stolen goods?

The Court of Appeal overturned the conviction. The defendant had never been in possession or control of the goods, so he never received them. Meanwhile, he did not aid or abet any offence since the relevant primary offences (theft and receipt of stolen property) were complete by the time he assisted the two men.

This Case is Authority For…

A person does not ‘receive’ stolen goods unless they had possession or control over the stolen goods.

Watson was charged under the old offence of ‘receiving’ stolen goods. The modern offence is ‘handling’ stolen goods under s.22 of the Theft Act 1968. This applies where the defendant ‘undertakes or assists in [the goods] retention, removal, disposal or realisation by or for the benefit of another person, or if he arranges to do so’. Under this new definition of ‘handling’, negotiating the sale of stolen goods would probably count as disposing the goods or arranging to dispose of the goods, but only if the goods were actually sold. Since Watson failed to secure a sale of the ring, he probably would not be convicted under the modern offence either. He might, however, be convicted of conspiracy to handle stolen goods.


A person cannot be an accessory to a crime if they only assisted after the crime was complete.