[2009] EWCA Crim 569

There was nothing in the wording of the Drug Trafficking Act 1994 that deprived the Crown Court of the power to make an order increasing the amount to be recovered under a confiscation order, even though the court had previously certified that the realisable amount was "nil" under s.17 and made an order to that effect.

CA (Crim Div) (Aikens LJ, Mackay J, Stadlen J)


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