Where an offence was committed before the insertion of s.71(9A) Criminal Justice Act 1988, a confiscation order could not be made in the Crown Court under s.71 of the 1988 Act where the defendant had pleaded guilty in the magistrates' court but had been committed to the Crown Court for sentence. * Overruled by the House of Lords in R v Alan Pope (2002) UKHL 26.

CA (Crim Div) (Tuckey LJ, Gage J, Judge Rivlin QC)


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