[2010] EWHC 1531 (Admin)

The value of gifts made by an offender should be included in the amount of a confiscation order even though the gifts were not themselves realisable by the offender, as the Crown could take enforcement steps against the donee. The offender was not therefore entitled to a certificate of inadequacy in relation to the value of assets given as a gift.

QBD (Admin) (Hickinbottom J)

23/06/2010