High Court Clarifies Time Limits for Low-Value Shoplifting in Jobson v DPP

On 5 June 2025, the High Court of Justice (King's Bench Division) issued a significant ruling in the case of Angelina Jobson v Director of Public Prosecutions ([2025] EWHC 1385 (Admin)). Presided over by Mrs Justice Hill, the judgement delves into the intricate matters surrounding the time limits applicable to prosecuting shoplifting offences, particularly in light of the stipulations set forth in Section 127 of the Magistrates’ Courts Act 1980. This ruling comes amid a backdrop of growing concerns regarding "low-value shoplifting" and how it is addressed within the legal framework.

Angelina Jobson, the appellant, challenged her conviction related to a 2023 incident involving the alleged theft of £88 worth of meat from a butcher's shop. Charges against her were registered on 26 October 2023, which raised the key issue of timing, as these fell outside the customary six-month limit for summary offences post-incident date. Jobson's appeal numbered among its central arguments the assertion that prosecuting her was time-barred, given that charges were brought beyond the legally defined timeframe for such offences.

In this case, precedent plays a vital role, particularly in reference to Candlish v DPP (2022), where the court articulated that a series of thefts viewed as a singular offence must still comply with a six-month limitation, provided the total value does not exceed £200. Jobson's defence hinged on the contention that her situation ought to be treated under the provisions for low-value shoplifting, thereby invoking the statute of limitations described in Section 127.

During the appeal proceedings, the court noted Jobson's claim was rooted in the alleged misapplication of statutory interpretations. Her argument maintained that the district judge made an error by concluding that the prosecution was not subject to time limitations. Conversely, the DPP referred to existing rulings in Candlish to illustrate that low-value shoplifting offences are regarded as indictable until the defendant's initial court appearance.

In her ruling, Mrs Justice Hill highlighted that this interpretation implies all theft offences, irrespective of their individual value, remain indictable until a magistrate's court makes a judicial decision. After thoroughly reviewing the circumstances surrounding Jobson's case, the judge adjudicated that the theft retained its classification as an indictable offence until her appearance in court, thus indicating the time limit in question was inapplicable.

The judgement notably clarifies that while low-value shoplifting is designated as a summary-only offence following judicial determination, it sustains its indictable classification until evaluated by a court. This legal interpretation not only reinforces the rights of defendants but also underlines the essentiality of proper judicial assessment, irrespective of the duration that has elapsed between the alleged infringement and the subsequent legal repercussions.

In summary, this ruling lends substantial clarity to the legal landscape concerning theft and shoplifting offences in the UK, asserting a stringent interpretation of existing time limits that solidifies defendants' rights while maintaining fidelity to established legal doctrines. By affirming the relevance of the Candlish precedents, the judgement serves as a crucial benchmark for future cases involving low-value theft, setting clear expectations for both prosecuting authorities and defendants. The decision contributes to ensuring a meticulous application of legal standards, thereby enhancing clarity and predictability in the realm of criminal law.