Ryan, R. v [2014] EWCA Crim 811 (08 April 2014)
The judge correctly applied the law and standard of proof in determining that the applicant's benefit exceeded £5,000, justifying the finding of a criminal lifestyle and the making of the confiscation order. There was no merit in the grounds of appeal regarding time limits, criminal lifestyle, or proportionality.
- Citation
- [2014] EWCA Crim 811
- Parties
- Prosecution: Regina; Applicant: Steven John Ryan
- Jurisdiction
- England and Wales
- Judgment Date
- 08 April 2014
- Procedural Posture
- Criminal Appeal / Renewed Application for Leave to Appeal Confiscation Order
- Outcome
- renewed application for leave to appeal refused
- Legal Topics
- Confiscation Order, Criminal Lifestyle, Benefit From Criminal Conduct, Time Limits for Confiscation, Proportionality
Case Brief
Summary, issues, holding and outcome
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Parties
Regina
Prosecution
Steven John Ryan
Applicant
Procedural Posture
Criminal Appeal / Renewed Application for Leave to Appeal Confiscation Order
Legal Issues
- 1 Whether the confiscation order was made out of time under section 14 of the Proceeds of Crime Act 2002
- 2 Whether the applicant had a criminal lifestyle under section 75 of the Proceeds of Crime Act 2002
- 3 Whether the confiscation order was disproportionate
Ratio Decidendi
The judge correctly applied the law and standard of proof in determining that the applicant's benefit exceeded £5,000, justifying the finding of a criminal lifestyle and the making of the confiscation order. There was no merit in the grounds of appeal regarding time limits, criminal lifestyle, or proportionality.
Court Disposition
renewed application for leave to appeal refused
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