The Crimminal Code Act 1899 defines the act of what is commonly known as an "Armed Hold-up" as a" Robbery" Section 409 states: "Any person who steals anything, and , at or immediately before or immediately after the time of stealing it, uses or threatens to use actual violence to any person or property in order to obtain the thing stolen or to prevent or overcome resistance to its being stolen, is said to be guilty of robbery".