In R v Vincent [2001] CA, V stayed for a week at one hotel and shortly afterwards he stayed for a month at another. In both cases he left without paying his bills. He told the court that he had told the owners of both hotels that he was waiting to receive some money and would then pay them. Thus, he believed that they had accepted the arrangement that he would make payment when he was able to do so. The Court of Appeal (Criminal Division) upheld an appeal that V was not guilty of an offence under Section 2 of the Theft Act. Although hotels normally required “on the spot payment”, that expectation did not apply where an agreement had been reached to pay later. Whether or not that agreement had been induced by deception, it did not amount to theft of services under the Theft Act.
