[2008] EWHC 3217 (Admin)

An application for a certificate of inadequacy under the Criminal Justice Act 1988 s.83, made on the basis that a defendant's realisable property was inadequate to meet a confiscation order because a third party had refused to return funds to the defendant, was refused where the irrecoverability matter could not, in the circumstances, be classed as a post-confiscation order event.

QBD (Admin) (David Holgate QC)

19/12/2008