EWCA Civ 1465
The Court of Appeal was bound by the decision in R. v Tivnan (Michael)  1 Cr. App. R. (S.) 92 to hold that the power in the Drug Trafficking Act 1994 s.16 to increase the amount of an offender's realisable assets post-conviction, for the purposes of satisfying a confiscation order, included after-acquired assets.
CA (Civ Div) (Arden LJ, Thomas LJ, Etherton LJ)