Bowie was a 10-week-old French Bulldog puppy who was being offered for sale at a Pet Store in Eastgardens. Bowie was exceptionally friendly, with a beautiful mix of white and lilac colouring making him rare and very valuable. Bowie was being advertised for sale at $6,000. Luke and Jacob, who had recently lost their jobs, saw that the pet store had posted photos of Bowie on Instagram. A quick search online for similar puppies indicated that Bowie could actually be worth over $9,000. Seeing an opportunity to make some quick cash, the two agreed that they would go to the pet store the next day and "get a hold" of Bowie so they could sell him for a higher price. The next day Luke drove to Jacob's house to pick him up. Jacob had transferred $3,000, the last of his savings, into his own spending account so he could withdraw the money to cover his half of Bowie's purchase price. Jacob was initially concerned about potentially losing the money if they couldn't sell Bowie, but was confident he would get the money back. He believed reselling Bowie for profit was a good opportunity to make some easy money and tide himself over until he got a new job. The pair arrived at the pet store. Prior to going inside, Luke, feeling a bit nervous, pulled out a large flask of whiskey from under his seat and drank it in one go. Jacob stared at him confused but didn't say anything. With Luke now feeling ready, he and Jacob got out of the car and proceeded to the pet store. Luke went to the sales associate, Sarah, and asked if they could hold Bowie as they were really interested in buying him. The sales associate unlocked the pen, lent in and grabbed Bowie. She handed him to Luke who nursed him and observed how beautiful he was. He then glanced at Jacob, who nodded in agreement. Moments later, Luke thrust Bowie into Jacob's hand and whispered, "We got him, run!" and began to push both out of the store. Jacob was taken by surprise and stared at Luke in shock but relented. Jacob held Bowie tightly and proceeded to run with Luke out of the store and into the parking lot. The pair sprinted towards Luke's car. On the way, Luke ran into Heather, a 54-year-old shopper, as she was collecting a trolley. He elbowed her with significant force to the stomach as he rushed to get past her that she fell backwards, suffering bruises all over her left hip. Without stopping to help, Jacob and Luke got into the car and drove away. As they exited the carpark Jacob looked at Luke and asked, "What did we just do? I had the money to pay for him!" Luke responded, "Well now we have more!"

Assess the criminal liability of Luke and Jacob.