[21] Section 343 specifies four ways in which robbery may be committed. It is not unusual to find that those who attempt to determine the meaning of s. 343(a) will contrast the wording of that paragraph with that of s. 343(b). For convenience I shall reproduce them both:
Every one commits robbery who
(a) steals, and for the purpose of extorting whatever is stolen or to prevent or overcome resistance to the stealing, uses violence or threats of violence to a person or property;
(b) steals from any person and, at the time he steals or immediately before or immediately thereafter, wounds, beats, strikes or uses any personal violence to that person;
…..
To state the obvious, for there to be a robbery, at least under (a) and (b), there must be a theft of something. The additional feature which turns theft into robbery can be generally described as the presence of violence or a threat of violence. Two differences between these two methods of committing robbery are evident. First, (b) deals with violence against the person from whom one steals, whereas the violence in (a) may be against a stranger. Second, in (a) the violence must be for one of the specified purposes, whereas under (b) the violence does not have to be for a specific purpose though it must be at the time of the theft or immediately before or immediately after. In respect of (b), I would note in passing that in Rick Libman, The Law of Robbery, (Toronto: Carswell, 1990), at pp. 92-93, the author observes, citing certain unreported cases, that “Courts have not been reluctant to give a liberal interpretation to the sufficiency of property interests in robbery cases, holding, for example, that a store manager, sales clerk or store security officer all possess a sufficient property interest in a pair of jeans, or similar merchandise.” See also, s. 588 of the Criminal Code.
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