R v Gullefer [1990] 1 WLR 1069

Court: Court of Appeal (Criminal Division)

Facts: D, a gambler, ran onto the racetrack to void a losing bet but did not yet demand his stake back.

Held: Appeal allowed, Conviction quashed. The court held that the act was merely preparatory and did not constitute an attempt to steal.

Key Judicial Statement: Lord Justice Dillon noted, "Merely taking preparatory steps is insufficient for an attempt; the act must be further along in the criminal process."