R v Ilyas [2008] EWCA Crim 1303, [2008] All ER (D) 301 (Jun)
The transfer of property to a defendant, through the fraudulent securing of a mortgage, represented a benefit obtained by him in connection with the offence and the statutory assumptions under the proceeds of crime legislation apply. For the assumptions to apply, it is not necessary for the prosecution to show that the defendant knew that the transfer of the property to him had been part of a fraudulent scheme.