Robbery is a special and aggravated form of either theft or extortion. The chief distinguishing element in the robbery is the presence of imminent fear of violence. The second paragraph distinguishes robbery from theft; the third distinguishes it from extortion. There can be no case of robbery which does not fall within the definition either of theft or of extortion; but in practice, it will perpetually be a matter of doubt whether a particular act of robbery was theft or extortion. A large proportion of robberies will be half theft, half extortion. When there is no theft, as a natural corollary, there cannot be robbery. Robbery is only an aggravated form of theft or extortion. Violence must be in the course of theft and not subsequently. Also, it is not necessary that violence should actually be committed, even an attempt to commit it is enough.

Dacoity is robbery committed by five or more persons; otherwise, there is no difference between dacoity and robbery. The gravity of the offence consists in the terror it causes by the presence of a number of offenders. Abettors who are present and aiding when the crime is committed are counted in the number. When five or more persons conjointly commit or attempt to commit a robbery, or where the whole number of persons conjointly committing or attempting to commit a robbery, and persons present and aiding such commission and attempt amount to five or more, every person so committing, attempting or aiding, is said to commit 'dacoity'. Section 396 IPC, 1860 brings within its ambit a murder committed along with 'dacoity'. In terms of this provision, if any one of the five or more persons, who are conjointly committing dacoity, commits murder in so committing dacoity, every one of those persons shall be punished. On a plain reading of these provisions, it is clear that to constitute an offence of 'dacoity', robbery essentially should be committed by five or more persons. Similarly, to constitute an offence of 'dacoity with murder' any one of the five or more persons should commit murder while committing the dacoity, then every one of such persons so committing, attempting to commit or aiding, by the fiction of law, would be deemed to have committed the offence of murder and be liable for punishment provided under these provisions depending upon the facts and circumstances of the case.