What did R v Robinson decide about attempts?

The court said an attempt needs acts which form part of the actual crime. Mere intention or remote steps are not enough.

Why was Robinson’s conviction quashed?

He had not yet done all that was needed to obtain the money. Important steps were still missing, so his acts were only preparation.

What is the preparation versus attempt test?

Ask if the acts go beyond setting up the plan and directly move to commit the crime. If not, it is preparation, not attempt.

Is mere intention a crime?

No. Intention alone is not criminal. There must be an overt act closely connected to the completed offence.

How to use this case in exams?

Quote R v Robinson for the rule that remote acts do not amount to attempt. Apply it when police intervention stops early-stage plans.

R v Robinson

CASE_TITLE: R v Robinson

PRIMARY_KEYWORDS: R v Robinson, attempt, false pretences, criminal attempt

SECONDARY_KEYWORDS: preparation vs attempt, police intervention, insurance claim, King’s Bench 1915

PUBLISH_DATE: 02 Nov 2025 · AUTHOR_NAME: Gulzar Hashmi · LOCATION: India

Quick Summary

This case draws the line between preparation and attempt. A jeweller staged a fake burglary to claim insurance money. Police found the “stolen” jewellery hidden in his shop and stopped the plan. The question was: had he legally “attempted” to obtain money by false pretences? The King’s Bench said no. He had not yet done all acts necessary to receive the money. His steps were still too remote. So, the conviction was quashed.

Issues

Can a person be guilty of attempt when police intervention stops the plan early?
Do the acts done form part of the crime itself, or are they only preparatory?

Rules

Attempt: An act done with intent to commit the crime, forming part of a series of acts that would constitute its commission if not interrupted.

Preparation vs Attempt: Remote steps or mere intention are not enough. The acts must directly connect to obtaining the property or money.

Facts (Timeline)

5 Nov 1914: A jeweller insured stock at Lloyd’s against burglary for twelve months (cover £1200).

11 Dec 1914 (morning): Police heard noises, entered the house, found the jeweller tied up; safe appeared emptied.

Statement: He told police he had been attacked at night and later found the jewellery gone.

Search: Officers discovered the jewellery hidden in a recess behind the safe.

Admission: He said war times were hard; he planned to claim insurance like a prior burglary payout.

Trial: Jury convicted him of attempting to obtain money by false pretences. He appealed.

Arguments

Appellant

Only preparation was done; no act directly claiming money was performed.
Many steps still remained before any payout could occur.

Respondent

Staging the burglary and giving a false story showed intent and overt acts.
Police intervention should not let a wrongdoer escape attempt liability.

Judgment

Appeal allowed. The conviction was quashed.

Before a person can be convicted of attempting to obtain money by false pretences, it must be shown that he has done all that is necessary on his part to enable him to receive it. Remote acts are not attempts.

Ratio

Core test: Do the defendant’s acts directly form part of the completed offence?

Application here: The jeweller had not yet made a claim or taken the final steps needed to receive the money. His conduct was still preparatory.

Why It Matters

Clarifies where the line is drawn between planning and attempting.
Useful for questions on police interruption and incomplete crimes.
Shows that intention + remote steps ≠ attempt.

Key Takeaways

Attempt needs proximity: Acts must closely and directly lead to the result.
Preparation is not enough: Tying oneself up and hiding goods is still remote.
Intervention timing matters: Early police stop may show no attempt yet.

Mnemonic + 3-Step Hook

Mnemonic: “PP→A: Prove Proximity to Attempt”

Plan? Identify the intention and preparatory steps.
Proximity? Ask if the act directly forms part of getting the money.
Attempt? Only if steps are immediate and nothing vital remains.

IRAC Outline

Issue

Did the jeweller’s acts amount to an attempt to obtain insurance money by false pretences?

Rule

An attempt is an act with intent that forms part of the crime itself; remote steps are not attempts.

Application

He staged a burglary and lied, but had not yet done the acts needed to receive the money (e.g., making and processing the claim).

Conclusion

No attempt; conviction quashed.

Glossary

False pretences: Obtaining property by a dishonest misrepresentation.
Attempt: Conduct that directly forms part of the offence and would complete it if not interrupted.
Preparation: Early steps that arrange or set up the plan, not yet part of the offence itself.