The scope of the certificate of inadequacy procedure under the Criminal Justice Act 1988 s.83 was limited and did not permit the court to revisit the findings made in confiscation proceedings. Where a defendant had accepted in confiscation proceedings that there were "hidden" assets, the court declined to issue a certificate simply on the ground that he appeared some years later to be impecunious.

QBD (Admin) (Blake J)

13/02/2014