The court had an inherent power to make an order requiring a defendant to repatriate personal assets as part of its inherent power to enforce restraint orders. There was no overlap between a sentence in default of a confiscation order and a sentence for contempt of court for non-compliance of a repatriation order.

CA (Civ Div) (Beldam LJ, Roch LJ, Judge LJ)

20/12/1999