"Procure" in s.20(2) of the Theft Act 1968 meant no more than "cause" or "bring about". A s.20(2) conviction could be substituted for a s.15(1) Theft Act 1968 conviction, because the mens rea was substantially the same.

CA (Crim Div) (Mantell LJ, Hooper J, Judge Michael Walker)

19/01/1998