Lawyers for the convicted thief - a repeat offender who was sentenced to 22 days in jail - had argued that leaving the bike unlocked amounted to entrapment. But the five-judge court has rejected that, saying the man wasn't personally targeted.
His name has not been released.
Police arrested him in Deventer in March 2006 after he took a bike they left near a train station that was being plagued by thefts.
Tuesday's court ruling said placing an unlocked decoy bike didn't make the suspect do anything he had not intended doing beforehand.