[2011] EWHC 461 (Admin)
Under the Proceeds of Crime Act 2002 s.242(2)(b), in a cash forfeiture case, a customs officer had to show that the property seized was obtained through conduct of one of a number of kinds, each of which would have been unlawful conduct. It was not sufficient for the officer to point to criminal conduct of an unspecified kind.
QBD (Admin) (Thomas LJ, Nicola Davies J)
11/03/2011