Saturday, 20 December 2014

Theft by Servant

Theft by Servant
Ever had that temptation to appropriate your employer’s funds? Ever heard that temptation to convert official money so as to buy that gigantic smart phone?
Well hope you resisted it because you would have committed an aggravated form of theft[1].Section 281 of the Penal Code[2] succinctly states that if the offender is a clerk or servant, and the thing stolen is the property of his employer, or came into the possession of the offender on account of his employer, he is liable to imprisonment for seven years.  From this we can deduce that the ingredients are;
1.      Offenders of this offence must be either clerks or servants( employees)
2.      Things capable of being stolen
3.      Fraudulent
4.      Stolen matter is employers property/or came into offenders possession by virtue of employer
This normally occurs when a master has entrusted goods to his servant and servant is known to have custody of the goods but not ownership. If money is received on someone’s behalf then it is the property of the person on whose behalf it has been received. 
Jurisprudence in this area states that;
1.      To determine whether someone is a servant we look at whether he/she is bound to obey his orders as to what work he should do and how he should do it[3]. Even conductors who take fare but give the employer a lesser sum are liable for theft by servant[4] as this money is gotten by virtue of his employer entrusting him this position.
2.      Things capable of being stolen[5]
3.      Fraudulent Taking/ Conversion: Fraudulent taking is the used in a manner that would be rejected by the employer. Thus it would not be theft if money given by employer was used in circumstances that would not be objected to by the owner[6] as this would negate the element of fraudulent taking. Conversion on the other hand is the using of something in such a way that is inconsistent with the owner’s rights.



[1] Uganda v Matovu (1974) EA 195(C.J Wambuzi)
[2] Chapter 63 Laws of Kenya
[3] Afzal Khan Awan v R (1958) EA 492
[4] Gakubu v Republic (1968)EA 395 (CJ Farrell)
[5] Section 267 Ibid (n 2)
[6] Yusuf v Republic (1970) EA 276 (C.J Georges)

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