Commentary for Kiddushin 116:6
ואיבעית אימא דכולי עלמא לית להו דשמואל והכא היינו טעמא דרבי דקנסוהו רבנן לגנב
and the other that they are not. Alternatively, all agree that they are regarded as separated, and disposal rights have no monetary value.
Daf Shevui to Kiddushin
The next explanation is that Rabbi Yehudah Hanasi simply penalizes the priest by making him have to pay back the full value of what he stole. Why should he luck out just because what he stole was tevel?
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