Practice and Procedure

R v JACK WALKER (2011)

PUBLISHED January 24, 2011

[2011] EWCA Crim 103

A life interest in one-third of a trust fund which had an immediate right to any income produced was "free property" and available for the purposes of confiscation pursuant to the Proceeds of Crime Act 2002 s.9(1)(a), but due to difficulties in calculating its value, which was likely to be low, it was appropriate to confirm the quantum of a confiscation order made without reference to it.

CA (Crim Div) (Hooper LJ, Etherton LJ, Openshaw J)