The wording of Section 22 actually creates eighteen ways in which handling may be committed, This may create a problem for prosecutors in that Rule 7 of the Criminal Procedure Rules 2005, and Rule 7 of the Indictments Rules 1971 provide that only a single offence may be charged in one information (in the Magistrates' Court) or in one count of an indictment (in the Crown Court). It can also be difficult to determine the meaning of "otherwise than in the course of stealing"; it was decided in R v Hale 1 Crim LR 596 that the "appropriation" in theft may be a continuing act, so it may be difficult to determine whether a theft has been completed.