Ryan, R. v

Ryan, R. v

There was no arguable merit in any of the grounds of appeal; the judge applied the correct legal standards and there was sufficient evidence to support the finding that the benefit exceeded £5,000 and the making of the confiscation order.

Parties
Prosecutor: 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 Crime, Time Limits, Proportionality
Criminal Law Proceeds of Crime Confiscation Order Criminal Lifestyle Benefit From Crime Time Limits Proportionality

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Parties

Regina

Prosecutor

Steven John Ryan

Applicant

Procedural Posture

Criminal Appeal / Renewed Application for Leave to Appeal Confiscation Order

Legal Issues

  1. 1 Whether the confiscation order was made out of time under section 14 of the Proceeds of Crime Act 2002
  2. 2 Whether the applicant had a criminal lifestyle under section 75 of the Proceeds of Crime Act 2002
  3. 3 Whether the confiscation order was disproportionate

Ratio Decidendi

There was no arguable merit in any of the grounds of appeal; the judge applied the correct legal standards and there was sufficient evidence to support the finding that the benefit exceeded £5,000 and the making of the confiscation order.

Court Disposition

renewed application for leave to appeal refused