Although a judge had excluded a French property from his assessment of an offender's benefit from criminal conduct, that did not mean that he had also excluded it from the offender's realisable assets. Registration of the property in France in the names of his two children pursuant to a deed of gift, which the English court held was fabricated, was not a reason to vary restraint and management receivership orders to exclude the property.

QBD (Admin) (Ouseley J)

18/07/2013