n Tydskrif vir die Suid-Afrikaanse Reg - Duplication of convictions in respect of simultaneous multiple robberies : regspraak




The scenario of multiple robberies committed simultaneously or within a very short period of time by the same person or a group of persons at a single venue and in respect of various victims, presents itself quite often. This is especially the case in respect of bank robberies where various individuals in the execution of a common purpose to rob a bank, enter the premises and in the process of robbing the personnel of money belonging to the bank also rob the personnel and/or clients in attendance of their personal effects. For purposes of the subsequent criminal trial the question arises whether the unlawful actions committed in respect of each individual victim should be formulated as a separate count of robbery or whether all the actions should be taken together and the accused be charged with a single count of robbery. If the accused was charged with separate counts of robbery, a further question then arises at the conclusion of the trial as to whether the accused may be convicted accordingly or whether a conviction on each of the robbery counts would constitute an unfair duplication of convictions.


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