[2012] EWHC 1231 (Admin)

An application for a certificate of inadequacy under the Criminal Justice Act 1988 s.83(1) was refused where evidence concerning the dissipation of tainted gifts identified in the order as realisable property was not sufficiently reliable to demonstrate on the balance of probabilities that a certificate should be granted, and in any event most of the material sought to be adduced could and should have been produced at the original confiscation hearing.

QBD (Admin) (Lindblom J)

29/03/2012