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England and Wales decisions
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Mirza v Crown Prosecution Service [2025] EWHC 3349 (Admin) (19 December 2025)
The High Court dismissed Zahid Mirza’s application for a certificate of inadequacy under s.83 Criminal Justice Act 1988, finding no proof of a genuine post-order change in assets.
The High Court dismissed Mr Mirza’s s.83 Criminal Justice Act 1988 application for a certificate of inadequacy, finding he was trying to re-open the original confiscation order.
The applicant failed to discharge the burden of proof under section 83 of the Criminal Justice Act 1988 because he provided no evidence as to what became of the hidden assets found by the Crown Court, nor any evidence that those assets had depreciated or were no longer available. The statutory regime does not permit the court to grant a Certificate of Inadequacy based solely on proportionality or hardship where the applicant has not engaged with the requirement to account for the hidden assets. Accordingly, the application must be dismissed.
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Pigott v Crown Prosecution Service [2024] EWHC 2177 (Admin) (20 August 2024)
The High Court refused Stephen Pigott’s application for a certificate of inadequacy under section 83 of the Criminal Justice Act 1988, finding he had not proved asset dissipation.
Daya v Crown Prosecution Service [2024] EWHC 1091 (Admin) (08 May 2024)
The High Court refused a certificate of inadequacy in a confiscation case, holding that the applicant failed to explain what happened to hidden assets or show a change in circumstances.
Price v Crown Prosecution Service [2022] EWHC 1278 (Admin) (26 May 2022)
The High Court dismissed Dr Simon Price’s applications to discharge a confiscation order and restraint order, and certified them as totally without merit.
The Administrative Court dismissed Dr Simon Price’s applications to discharge a confiscation order and a restraint order, certifying them as totally without merit.
Asplin & Ors, R. v (Consequential Matters) [2022] EWCA Crim 9 (13 January 2022)
The Court of Appeal varied confiscation and compensation orders after reconsidering pension assets, tax treatment, and loss figures arising from a conspiracy to defraud.
The High Court dismissed an application for a certificate of inadequacy under section 83 of the Criminal Justice Act 1988, finding the applicant had not proved his realisable property was insufficient.
O'Connor v Crown Prosecution Service [2021] EWHC 2900 (Admin) (02 November 2021)
The High Court dismissed an application for a certificate of inadequacy under section 83 of the Criminal Justice Act 1988, finding the applicant had not proved his assets were insufficient.
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