It was not necessary for the Crown to establish a prima facie case as to unexplained proceeds alleged to be from criminal activity in order for confiscation orders to apply. The confiscation provisions were not in conflict with European Convention on Human Rights 1950 Art.6(2) because the presumption of innocence was not violated where a defendant had the opportunity to rebut assumptions.

CA (Waller LJ, Butterfield J, Judge Allen)

14/05/1999