[2011] UKSC 49

In civil recovery proceedings, it did not breach the European Convention on Human Rights 1950 art.6 for the court to apply the civil standard of proof in determining under the Proceeds of Crime Act 2002 s.241(3) whether property recovered was the product of criminal conduct on the part of the defendants. Further, an order for costs made in favour of the Serious Organised Crime Agency against a person against whom a recovery order had been made could include the investigation costs incurred by an interim receiver.

SC (Lord Phillips (President), Lord Brown JSC, Lord Mance JSC, Lord Judge JSC, Lord Clarke JSC, Lord Dyson JSC, Lord Reed JSC)

26/10/2011