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England and Wales Case Law

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Criminal law [2025] EWHC 3349 (Admin)

Mirza v Crown Prosecution Service

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.

  • Confiscation orders
  • Certificate of inadequacy
  • Realisable assets
  • Hidden assets
  • Criminal benefit
  • Enforcement of confiscation orders
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Criminal law [2022] EWHC 1204 (Admin)

Crown Prosecution Service v Iqbal

Crown Prosecution Service v Iqbal [2022] EWHC 1204 (Admin) (19 May 2022)

The High Court granted a certificate of increase under section 16(2) of the Drug Trafficking Act 1994 after finding the defendant held further realisable assets.

  • Confiscation order
  • Drug trafficking
  • Money laundering
  • Realisable assets
  • Certificate of increase
  • Confiscation-order
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Criminal law

CROWN PROSECUTION SERVICE v RAJA PARVEZ IQBAL

The High Court granted a certificate of increase after finding the defendant’s realisable assets exceeded the amount taken into account in a 2009 confiscation order.

  • Confiscation order
  • Drug trafficking
  • Money laundering
  • Realisable assets
  • Certificate of increase
  • Confiscation-order
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Criminal law [2022] EWCA Crim 9

Asplin & Ors, R. v (Consequential Matters)

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.

  • Confiscation orders
  • Compensation orders
  • Calculation of benefit
  • Realisable assets
  • Pension forfeiture
  • Taxation of pension withdrawals
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Criminal law [2020] EWHC 923 (Admin)

Ojebode (aka Benedicta Ojebode Oluremilekun Thomas), Criminal Justice Act 1988

Ojebode (aka Benedicta Ojebode Oluremilekun Thomas), Criminal Justice Act 1988 [2020] EWHC 923 (Admin) (17 April 2020)

The High Court considered whether Benedicta Ojebode’s remaining assets were inadequate to meet an outstanding confiscation order under section 83 of the Criminal Justice Act 1988.

  • Confiscation orders
  • Certificate of inadequacy
  • Realisable assets
  • Post-conviction relief
  • Certificate-of-inadequacy
  • Confiscation-orders
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Criminal law

Adams v Crown Prosecution Service (CPS)

Appeal against refusal of a certificate of inadequacy under section 83 of the Criminal Justice Act 1988. The Court of Appeal held the appellant had not proved his assets were inadequate.

  • Confiscation order
  • Certificate of inadequacy
  • Burden of proof
  • Realisable assets
  • Concealment of assets
  • Certificate-of-inadequacy
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Criminal law [2017] EWCA Crim 421

Nevitt, R v

Nevitt, R v [2017] EWCA Crim 421 (14 March 2017)

The Court of Appeal refused a nearly eight-year out-of-time appeal challenge to a confiscation order made against an absconding defendant.

  • Confiscation order
  • Absconding defendant
  • Extension of time
  • Criminal justice act 1988
  • Notice requirements
  • Realisable assets
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Criminal law

Gangar & Anor v Serious Fraud Office

The High Court dismissed two applications for certificates of inadequacy under section 83 of the Criminal Justice Act 1988 in confiscation proceedings.

  • Certificate of inadequacy
  • Realisable assets
  • Confiscation orders
  • Burden of proof
  • Post-confiscation events
  • Certificate-of-inadequacy
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Criminal law [2015] EWHC 446 (Admin)

Gangar & Anor v Serious Fraud Office

Gangar & Anor v Serious Fraud Office [2015] EWHC 446 (Admin) (25 February 2015)

The High Court dismissed two applications for certificates of inadequacy under s.83 CJA 1988, finding the applicants had not shown that their realisable assets were insufficient.

  • Confiscation orders
  • Certificate of inadequacy
  • Realisable assets
  • Enforcement of criminal orders
  • Certificate-of-inadequacy
  • Confiscation-orders
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Criminal law

Godley, R v

Confiscation proceedings arising from a fraud conviction. The court fixed Mr Godley’s benefit, included gifts to family members as realisable assets, and made confiscation and compensation orders.

  • Confiscation proceedings
  • Benefit from criminal conduct
  • Realisable assets
  • Gifts under proceeds of crime
  • Compensation orders
  • Confiscation-proceedings
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