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The decision of the House of Lords in the Preddy appeal has led to a string of appeals against conviction to the Court of Appeal from individuals convicted under s.15 Theft Act 1968. On 25th October the Court of Appeal quashed the convictions of seven such appellants as being rendered unsafe in law by the Preddy judgment. In the course of their decision the Court of Appeal outlined alternative charges which may be appropriate in cases of dishonestly obtaining funds now that the use of s.15 has been curtailed by the decision in Preddy. These are: theft; false accounting contrary to s.17 Theft Act 1968; evasion of liability by deception contrary to s.2 Theft Act 1978; procuring the execution of a valuable security contrary to s.20 Theft Act 1968; obtaining services by deception contrary to s.1 Theft Act 1978 (a less attractive option after R v Halai 1983); conspiracy to defraud; attempts.