Features of liability for violent plunder of other person's property in foreign criminal law

The article provides a comparative analysis of responsibility for violent theft in the criminal law of a number of countries of common and continental law. It is shown that there are no differences in the qualifications of responsibility for violent embezzlement, depending on the nature of the violence, in all cases the act, when using violence, is qualified as robbery. With the exception of UK criminal law, where robbery is understood as a material composition, in other countries, violent theft is recognized as completed from the moment of the attack. It is shown that in common law countries the public danger of violent embezzlement is associated, first of all, with an encroachment on property, in countries of continental law it is associated with a personal threat. In Russian criminal law, the public danger of violent embezzlement is associated, first of all, with encroachment on property, but, depending on the nature of the encroachment on a person as an additional object, a distinction is made between robbery and robbery. This differentiation is a feature of Russian criminal law.