[2014] EWCA Crim 227

On the facts, it was neither unjust nor unfair for the court to consider exercising its power to make a substitute confiscation order under the Criminal Justice Act 1988 in place of one that was invalidly made under the Proceeds of Crime Act 2002.

CA (Crim Div) (Pitchford LJ, Wilkie J, Patterson J)

21/02/2014

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