the Theft Act 1968 by treating "appropriation" as a neutral word comprehending "any assumption by a person of the rights of an owner". In other words, it is immaterial whether the act was done with the owner's consent or authority. His Lordship then turned to the appellant's arguments. Counsel had argued that the effect of the decisions in R v Lawrence and R v Gomez was to reduce the actus reus of theft to a "vanishing point". Lord Steyn was unconvinced by these arguments and maintained that the House of Lords had not overlooked the consequences in its previous decisions. His Lordship was motivated by a concern that if the law is restated by adopting a narrower definition of appropriation, the outcome is likely to place beyond the reach of the criminal law dishonest persons who should be found guilty of theft. Counsel for the defendant also highlighted the conflict between civil and criminal law that would result from a broad interpretation of the word "appropriates", along with the "grotesque and absurd" results that such a decision would allow. Lord Steyn, however, accepted that in a practical world there would always be a disharmony between the two systems and noted that in this disharmony it is not necessarily the criminal law that is defective. He therefore declined to depart from the rulings in R v Gomez and R v Lawrence. His Lordship pointed out that the mental requirements of the law of theft offer adequate protection from the injustice that would otherwise result from a broad interpretation of the word "appropriates". For these reasons, Lord Steyn rejected the appellant's counsel's argument that the law as expounded in R v Gomez and R v Lawrence must be qualified to say that there can be no appropriation unless the other party (the owner) retains some proprietary interest, or the right to resume or recover some proprietary interest, in the property. He also declined to accept the counsel's alternative argument that "appropriates" should be interpreted as if the word "unlawfully" preceded it. Lord Hutton Lord Hutton gave one of the two dissenting judgments. The other was made by Lord Hobhouse. His Lordship was in agreement with Lord Steyn as to whether there had been an appropriation. Although not directly relevant to the issue put before the court, he then went on to consider the element of dishonesty. He held that it was contrary