[2004] EWHC 176 (Admin)

In establishing that the value of his realisable assets had decreased since the date of the confiscation order, the burden of proof lay with a defendant seeking a certificate of inadequacy to satisfy the court as to what he had done with a sum withdrawn from a bank account and as to the income and fruits of that money.

QBD (Admin) (Lightman J)

10/02/2004