[2009] EWCA Crim 1303

For the purpose of making a confiscation order the value of the benefit obtained by an offender who had been guilty of managing a company as a director in contravention of a director disqualification order, or an undertaking not to act as a director, was not necessarily the turnover of the relevant company or companies but the real benefit the offender had obtained personally.

CA (Crim Div) (Aikens LJ, Hedley J, Hickinbottom J)

26/06/2009