The labour theory of property holds that creation is the source of property rights. This is incorrect, as it is not creation but scarcity which gives birth to property rights.1
Creation itself is not sufficient to justify ownership in something. In order to create some scarce resource one must utilise other scarce materials found in nature, however such materials are not owned under this theory as they were not created. This is problematic as in order to justly direct the materials to create the desired resource, one must own said materials.1