Property can cease to belong to another if it has been abandoned. However, the courts do not readily find that property has been abandoned. In Williams v Phillips (1957) 41 Cr App R 5), it was held that a householder does not abandon goods that he puts in his dustbin. He intends the goods to be collected by the local authority, so a dustman could be guilty of theft if he appropriates goods from a dustbin with the relevant mens rea.