Reference for Bava Kamma 228:4
מני אי רבנן קשיא גזלן אי ר"ש קשיא גנב
in which case ownership is not transferred, or did he perhaps mean to [make him subject to the law applicable to a] robber as defined by R. Simeon,<span class="x" onmousemove="('comment',' Who holds that there is Renunciation in the case of a robber. ');"><sup>1</sup></span>
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