COURT OF APPEAL(¹) 19 January 1899 MM. Saleh Sabet Pasha (Pres.); Willmore, Ali Zoulficar Bey, Cheikh Muhammad Abdou, Halton (JJ.); Elias Awad Bey (State Rep.). STATE REPRESENTATIVE v. AHMAD EL SAYED (P. C. Art. 287 and follg.). Theft—Aggravating circumstances—Completed offence—Violence. An act of violence committed by the thief after the completion of the theft, and with the sole object of making his escape, does not constitute an aggravating circumstance of theft but a distinct offence. (²) So a person who, after committing a theft in one house, in the course of his escape employs violence against someone who tries to arrest him in the garden of a neighbouring house, is not guilty of the crime of theft with violence. (¹) This decision confirms a judgment of the Tribunal of Cairo, 9 November 1898 (MM. Youssef Bey Sidki (Prés.); Mosely, Fouad Bey Greiss (JJ.); Muhammad Effendi Badreddine (State Rep.) reproduced below, the Court of Appeal adopting the motives contained in the latter judgment. (²) If this judgment is compared with a decision of the Court of Appeal dated 16 June 1894 (El Cada III, 382), it will be seen that violence can constitute an aggravating circumstance in the case of theft "if it immediately follows the theft," but that this theory must not be extended to cover a case where violence is employed to ensure escape in circumstances similar to those above set out.