of the prosecutor. if dealt with as an indictable offence, it is punishable by imprisonment for not more than 2 years, and, if treated as a summary conviction offence, it is punishable by 6 months imprisonment, a fine of $2000 or both. Where a motor vehicle is stolen, Section 333.1 provides for a maximum punishment of 10 years for an indictable offence (and a minimum sentence of six months for a third or subsequent conviction), and a maximum sentence of 18 months on summary conviction. Hong Kong Section 2 of the Theft Ordinance provides the general definition of theft in Hong Kong: The elements of this offence in Hong Kong is almost the same as in England and Wales, because the Theft Ordinance in Hong Kong was drafted based on the Theft Act 1968 (and the Theft Act 1978) in UK. However, the "Ghosh Test" for dishonest in Hong Kong has been replaced by the "Ivey Test" in England and Wales by the Supreme Court. It is the main difference between the offence of theft in these two jurisdictions. India Theft is a criminal activity in India with punishments which may lead to jail term. Below are excerpts of laws of Indian penal Code which state definitions and punishments for theft. Section 378 – Theft. Whoever intending to take dishonestly any movable property out of the possession of any person without that person’s consent, moves that property in order to such taking is said to commit theft. Explanation 1.—A thing so long as it is attached to the earth, not being movable property, is not the subject of theft; but it becomes capable of being the subject of theft as soon as it is severed from the earth. Explanation 2.—A moving effected by the same act which effects the severance may be a theft. Explanation 3.—A person is said to cause a thing to move by removing an obstacle which prevented it from moving or by separating it from any other thing, as well as by actually moving it. Explanation 4.—A person, who by any means causes an animal to move, is said to move that animal, and to move everything which, in consequence of the motion so caused, is moved by that animal. Explanation 5.—The consent mentioned in the definition may be express or implied, and may be given either by the person in possession, or by any person