Re L [2010] EWHC 1531 (Admin) (23 June 2010)

Re L [2010] EWHC 1531 (Admin) (23 June 2010)

The statutory scheme requires the value of gifts caught by the Act to be included in the amount of a confiscation order, and the inability of the defendant to realise such a gift does not entitle him to a certificate of inadequacy under section 17.

Source-derived case information.

Citation
[2010] EWHC 1531 (Admin)
Parties
Applicant: L; Respondent: Crown
Jurisdiction
England and Wales
Judgment Date
23 June 2010
Procedural Posture
Application for Certificate of Inadequacy Under Drug Trafficking Act 1994 / High Court Judgment on Application
Outcome
Application refused
Legal Topics
Confiscation Orders, Drug Trafficking, Certificates of Inadequacy, Gifts Caught by the Act, Enforcement of Confiscation Orders
Criminal Law Proceeds of Crime Confiscation Orders Drug Trafficking Certificates of Inadequacy Gifts Caught by the Act Enforcement of Confiscation Orders

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Parties

L

Applicant

Crown

Respondent

Procedural Posture

Application for Certificate of Inadequacy Under Drug Trafficking Act 1994 / High Court Judgment on Application

  1. 1 Whether the value of a gift caught by the Drug Trafficking Act 1994 can be excluded from the calculation of realisable property for the purposes of a certificate of inadequacy under section 17
  2. 2 Whether inability of the defendant to realise a gift made to a third party entitles him to a certificate of inadequacy

Ratio Decidendi

The statutory scheme requires the value of gifts caught by the Act to be included in the amount of a confiscation order, and the inability of the defendant to realise such a gift does not entitle him to a certificate of inadequacy under section 17.

Court Disposition

Application refused