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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 appellant actively consented to the confiscation order, instructed his lawyers to seek it, and was aware of the questionable value of the assets included. The circumstances do not amount to the most exceptional required to set aside a consent order. The appeal is dismissed.
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Butler v R. (Rev1) [2025] EWCA Crim 1 (13 January 2025)
Appeal against a consent confiscation order dismissed. The court held the appellant knowingly agreed figures he knew were unsustainable and no exceptional unfairness was shown.
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.
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 his assets were insufficient.
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.
The Court of Appeal partly allowed an appeal against a confiscation order, deducting HMRC cheque payments of £42,675.34 but rejecting a double-counting challenge.
Briah, R. v [2022] EWCA Crim 1818 (02 December 2022)
The Court of Appeal partly allowed a confiscation-order appeal after fresh evidence showed HMRC cheque payments totalling £42,675.34 should be deducted.
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