4. LEGAL INTERNATIONAL:
Singapore:
In Singapore, the law on offenses involving theft is primarily governed by the Theft Act, which is contained in the Penal Code (Chapter 224).
Under the Theft Act, theft is defined as the dishonest taking of property belonging to another person with the intention of permanently depriving the person of it. The maximum punishment for theft is 7 years' imprisonment, and the minimum punishment is 3 years' imprisonment for a first offense of theft of property valued at more than SGD 50,000.
In addition to theft, there are several other offenses related to theft in Singapore, such as robbery, housebreaking, and cheating. These offenses are also covered under the Penal Code and carry different penalties depending on the severity of the offense.
For example, robbery, which involves using force or the threat of force to steal property from another person, carries a minimum punishment of 5 years' imprisonment and can result in life imprisonment or even the death penalty in certain circumstances. Housebreaking, which involves breaking into a building with the intent to commit an offense, carries a maximum punishment of 14 years' imprisonment. Cheating, which involves dishonestly inducing another person to part with property, carries a maximum punishment of 10 years' imprisonment.
https://sso.agc.gov.sg//Act/PC1871?ViewType=Advance&Phrase=theft&WiAl=1
Saudi Arabia:
In Saudi Arabia, theft is considered a serious crime and is punished severely under Islamic law. The text law for theft in Saudi Arabia is based on Sharia law and is outlined in the country's Islamic criminal code.
According to the law, the punishment for theft is amputation of the offender's right hand, unless the theft was minor or the offender repents sincerely. In cases of repeated theft, the punishment may be amputation of the left foot. The law also allows for other penalties, such as imprisonment or fines, depending on the circumstances of the crime.
Russia:
Theft in Russia is governed by Article 158 of the Criminal Code of the Russian Federation. According to this law, theft is defined as the unlawful taking of another person's property without the owner's consent, with the intention of possessing it for oneself or someone else. The punishment for theft depends on the value of the stolen property, ranging from fines to imprisonment for a period of up to 10 years. In some cases, theft may also be punishable by forced labor, community service, or restriction of liberty. Additionally, if the theft is committed in a group, using violence, or involving the use of weapons, the penalties may be increased.
https://www.consultant.ru/document/cons_doc_LAW_10699/
China:
China's criminal law includes provisions for offenses involving theft. The law distinguishes between two types of theft: "theft" (盗窃) and "robbery" (抢劫).
Theft is defined in Article 264 of China's Criminal Law as the act of stealing property or other things of value from another person. The severity of the offense and the potential punishment depends on the value of the stolen property, with higher value property resulting in more severe punishments.
Robbery, on the other hand, is defined in Article 263 of China's Criminal Law as the use of violence, coercion, or other methods to take property from another person. Robbery is considered a more serious offense than theft and carries heavier penalties, including possible life imprisonment or the death penalty.
Overall, China's criminal law takes offenses involving theft seriously and imposes significant penalties for those found guilty of such crimes.
Turkey:
The legal system in Turkey is based on the civil law system, and the laws related to theft are included in the Turkish Penal Code. The relevant articles of the Turkish Penal Code regarding offenses involving theft are Articles 141 to 148.
Article 141 defines theft as the act of taking movable property that belongs to someone else with the intention of unlawfully appropriating it. The punishment for theft is imprisonment for a term of three months to five years. The punishment may be increased if the theft is committed in a residential or workplace, if the theft involves the use of force or threats, or if the stolen item is valuable.
Articles 142 to 148 deal with other forms of theft and related offenses such as embezzlement, fraud, and extortion. The penalties for these offenses range from fines to imprisonment for up to ten years.
https://www5.tbmm.gov.tr/kanunlar/k5237.html
France:
In France, theft is covered under the French Penal Code. The following articles of the code outline offenses involving theft:
Article 311-1: defines theft as taking someone else's movable property with the intention of appropriating it for oneself, without the owner's consent.
Article 311-2: states that if the theft is committed with the use of violence, threats, or coercion, the punishment can be up to 10 years in prison and a fine of up to 150,000 euros.
Article 311-3: provides for harsher penalties if the theft is committed by a person who is part of a criminal organization.
Article 311-4: makes it a criminal offense to receive, hide, or purchase stolen property, knowing that it has been stolen. This offense is punishable by up to 5 years in prison and a fine of up to 375,000 euros.
Article 311-5: defines aggravated theft, which is committed under certain circumstances, such as during the night, using a weapon, or in a place accessible to the public. The penalty for aggravated theft is up to 20 years in prison and a fine of up to 300,000 euros.
It's worth noting that French law also makes a distinction between theft and larceny. Larceny is a more minor offense that involves taking something without violence or coercion, and is punished with a lesser penalty.
United Kingdom:
Theft is a criminal offense in the United Kingdom and is governed by the Theft Act 1968. The Act defines theft as dishonestly appropriating property belonging to another with the intention of permanently depriving the other of it. It also defines a number of related offenses, such as handling stolen goods and making off without payment. The maximum penalty for theft is seven years imprisonment.
https://www.legislation.gov.uk/ukpga/1968/60/contents
Germany:
In Germany, the main legal provisions regarding theft are contained in Sections 242 to 248c of the German Criminal Code (Strafgesetzbuch or StGB). These sections define the offense of theft, the penalties for theft, and other related offenses such as embezzlement and robbery.
Section 242 of the German Criminal Code defines theft as the unlawful taking of movable property with the intention of appropriating it for oneself or for a third party. This section also covers other forms of theft, such as the theft of electricity, gas, and other forms of energy.
The penalties for theft in Germany depend on various factors, such as the value of the stolen property, the circumstances of the crime, and the offender's criminal record. Section 243 of the Criminal Code sets out the basic penalties for theft, which range from fines to imprisonment for up to five years. In cases of aggravated theft, such as theft with the use of violence or the theft of particularly valuable property, the penalty may be up to ten years in prison.
In addition to theft, the German Criminal Code also criminalizes related offenses such as embezzlement (Section 246), fraud (Section 263), and robbery (Section 249). Embezzlement involves the unlawful appropriation of property by someone who is entrusted with it, such as an employee or an agent. Fraud involves the intentional deception of another person in order to obtain property or a financial advantage. Robbery involves the use of violence or threats of violence in the course of a theft.
Overall, the German legal system takes theft very seriously and provides for significant penalties for offenders.
https://www.gesetze-im-internet.de/englisch_stgb/index.html
Italy:
The criminal law in Italy regarding offenses involving theft is covered in the Italian Criminal Code (Codice Penale Italiano). The relevant articles in the Italian Criminal Code are articles 624 to 637-bis.
Article 624 describes the offense of theft and establishes the punishment for those who commit this crime. The article defines theft as the taking of movable property belonging to another person, with the intent to appropriate it and without the owner's consent.
Article 625 describes the circumstances that can aggravate the crime of theft and increase the penalty for the offender. These circumstances include the use of weapons or violence, theft committed during the nighttime, theft committed in a public place, and theft committed by a group of people.
Article 626 covers the offense of attempted theft, which occurs when someone tries to steal something but is not successful.
Article 627-bis establishes the punishment for receiving stolen goods. The article defines the offense as the acquisition or possession of stolen property, knowing that it was obtained through a criminal offense.
Article 628 covers the offense of robbery, which occurs when someone steals using violence or threats of violence against another person.
Article 629 covers the offense of extortion, which occurs when someone uses violence or threats of violence to force another person to give them something of value.
Article 630 describes the crime of usury, which is the practice of lending money at excessively high interest rates.
These are some of the key articles in the Italian Criminal Code that relate to offenses involving theft.
Spain:
In Spain, offenses involving theft are covered under the Criminal Code. The relevant articles are Articles 234 to 237.
Article 234 defines the offense of theft as "the taking of someone else's property without their consent, with the intention of unlawfully appropriating it, regardless of the means used to obtain it."
Article 235 outlines the penalties for theft, which depend on the value of the property stolen and other factors such as whether the offense was committed in a dwelling or in a public place.
Article 236 covers the offense of robbery, which is defined as using violence or intimidation to steal property from someone. The penalties for robbery are more severe than those for theft.
Article 237 covers the offense of receiving stolen property, which is defined as acquiring or holding property that has been stolen. The penalties for receiving stolen property are also severe, and can include imprisonment.
Thailand:
In Thailand, the primary law governing offenses involving theft is the Penal Code, which is divided into two parts: General Provisions and Specific Offenses. The specific offenses include theft, embezzlement, fraud, and misappropriation of property.
Under Section 334 of the Penal Code, theft is defined as "the taking of another person's property for oneself or for another person, by using any means." The law also includes several factors that can increase the severity of the offense, such as breaking into a building to steal, stealing property worth over a certain amount, or using violence or threat of violence to commit the theft.
The penalties for theft in Thailand depend on the value of the stolen property and other factors. For example, if the stolen property is worth less than 5,000 baht (approximately $150 USD), the offender may face a maximum penalty of one year in prison or a fine of up to 2,000 baht (approximately $60 USD). However, if the stolen property is worth more than 100,000 baht (approximately $3,000 USD), the offender may face a maximum penalty of five years in prison or a fine of up to 10,000 baht (approximately $300 USD). In some cases, the offender may face both a prison sentence and a fine.
https://ratchakitcha.soc.go.th
Indonesia:
In Indonesia, the law on offenses involving theft is governed by the Indonesian Criminal Code. Article 362 of the Indonesian Criminal Code states that anyone who takes another person's property with the intention of taking it away from its rightful owner can be charged with theft. The punishment for theft in Indonesia can include imprisonment for up to five years, as well as fines. Additionally, the severity of the punishment can be increased if the theft was committed with the use of force or if the stolen property was of significant value.
https://www.globalanimallaw.org/downloads/database/national/indonesia/Indonesia-Penal-Code-1982.pdf
Japan:
Theft in Japan is covered by the Criminal Code of Japan. Article 235 of the Criminal Code defines theft as the act of taking someone else's property with the intent to steal it. The penalty for theft in Japan can vary depending on the value of the stolen property and other circumstances. For example, theft of property worth less than 50,000 yen is punishable by imprisonment for up to three years or a fine of up to 500,000 yen, or both. Theft of property worth more than 500,000 yen is punishable by imprisonment for up to ten years. If the theft is committed by a group of people, the punishment may be increased.
https://www.japaneselawtranslation.go.jp/en/laws/view/3581/en
United Arab Emirates:
Theft is a criminal offense in the United Arab Emirates (UAE) and is governed by Federal Law No. 3 of 1987 on the issuance of the Penal Code. Under the UAE Penal Code, theft is defined as taking possession of movable property that belongs to someone else, with the intent to permanently deprive them of that property.
The penalty for theft in the UAE varies depending on the value of the stolen property. If the value of the stolen property is less than 3,000 dirhams (approximately $815), the punishment can be up to 3 years in prison and/or a fine of up to 10,000 dirhams (approximately $2,725). If the value of the stolen property is 3,000 dirhams or more, the punishment can be up to 7 years in prison and/or a fine of up to 30,000 dirhams (approximately $8,180). In certain circumstances, such as theft committed during a natural disaster or theft committed by a public servant, the punishment can be more severe, including up to life imprisonment.
Nigeria:
Theft is a criminal offense under the Nigerian Criminal Code. The relevant section of the Criminal Code is Section 390, which defines theft as follows:
"A person who fraudulently takes anything capable of being stolen, or fraudulently converts to his own use or to the use of any other person anything capable of being stolen, is said to steal that thing."
The punishment for theft in Nigeria is imprisonment for a term of not less than 7 years and not more than 14 years, depending on the circumstances of the offense. For example, if the theft is committed by a servant or clerk, or in a dwelling house or place of worship, the offender may be punished with imprisonment for life. Additionally, the court may order the offender to pay restitution to the victim or to forfeit any property that was stolen.
https://jurist.ng/criminal_code_act/sec-390
Kuwait:
The Kuwait Penal Code includes provisions on offenses involving theft. Article 218 states that "Any person who takes possession of movable property of another with the intention of taking it without the owner’s consent shall be sentenced to a term of imprisonment not exceeding three years and to a fine not exceeding three thousand dinars, or to either of these penalties." Additionally, Article 221 provides that "Any person who takes possession of movable property of another with the intention of taking it without the owner’s consent and by means of deception shall be sentenced to a term of imprisonment not exceeding seven years and to a fine not exceeding seven thousand dinars, or to either of these penalties."
India:
The Indian Penal Code, 1860 deals with offenses involving theft in India. Section 378 to 382 of the IPC describe the offenses and their punishments. Here are the brief explanations of these sections:
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.
Section 379: Punishment for theft. Whoever commits theft shall be punished with imprisonment of either description for a term which may extend to three years, or with fine, or with both.
Section 380: Theft in a dwelling house, etc. Whoever commits theft in any building, tent or vessel, which building, tent or vessel is used as a human dwelling, or used for the custody of property, shall be punished with rigorous imprisonment for a term which may extend to seven years, and shall also be liable to fine.
Section 381: Theft by clerk or servant of property in possession of master. Whoever, being a clerk or servant, or being employed in the capacity of a clerk or servant, commits theft in respect of any property in the possession of his master or employer, shall be punished with imprisonment of either description for a term which may extend to seven years, and shall also be liable to fine.
Section 382: Theft after preparation made for causing death, hurt or restraint in order to the committing of the theft. Whoever commits theft, having made preparation for causing death, or hurt, or restraint, or fear of death, or of hurt, or of restraint, to any person who may resist or oppose the commission of such theft, shall be punished with rigorous imprisonment for a term which may extend to ten years, and shall also be liable to fine.
Morocco:
In Morocco, the law regarding offenses involving theft is the Penal Code (Dahir n° 1-75-407 of 25 Shawwal 1395), specifically Articles 375 to 400. These articles outline the different types of theft, including theft by force, theft with the use of a key, and theft by fraudulent means. Penalties for theft can include imprisonment and fines.
Pakistan:
The laws on offenses involving theft in Pakistan are outlined in the Pakistan Penal Code. According to the Code, theft is defined as the dishonest taking of property out of the possession of any person without that person's consent, with the intention of depriving the person permanently of the property. The penalty for theft varies depending on the value of the stolen property:
If the value of the stolen property is less than 10,000 rupees, the penalty is imprisonment for up to 3 years and/or a fine.
If the value of the stolen property is 10,000 rupees or more but less than 25,000 rupees, the penalty is imprisonment for up to 5 years and/or a fine.
If the value of the stolen property is 25,000 rupees or more but less than 100,000 rupees, the penalty is imprisonment for up to 7 years and/or a fine.
If the value of the stolen property is 100,000 rupees or more, the penalty is imprisonment for up to 14 years and/or a fine.
The Code also provides for more severe penalties in cases where certain aggravating factors are present, such as the use of violence or the commission of theft in a place of worship.