R v Ali [2014] EWCA Crim 1658, [2014] All ER (D) 30 (Aug)
The defendant appealed against a confiscation order against him in the sum of £1,438,180.59 for failing to comply with an enforcement notice for converting a house into 12 flats. The Court of Appeal, Criminal Division, in allowing the appeal held that any rents or proceeds derived from tenants in such properties prior to the expiry of any enforcement notice period could not, in law, constitute relevant proceeds of criminal conduct for the purposes of the Proceeds of Crime Act 2002. Accordingly, the confiscation order would be substituted by one in the total sum of £544,358.