The court determined that there were exceptional circumstances to justify going behind a confiscation order which had been made by consent. At the time of agreeing to the order, the defendant had wrongly been told that the judge had excluded the possibility of an adjournment, which could have allowed him to reduce his realisable assets figure.

CA (Crim Div) (Laws LJ, Sweeney J, Judge Goldstone QC) 24/5/2011
[2011] EWCA Crim 1488