“This case arose from a fairly extreme version of what is sometimes euphemistically described as CV padding. In short, the defendant had obtained a succession of prestigious public sector positions on the basis of application forms in which he described his educational qualifications and professional career in a way which bore absolutely no relation to reality. This was one of the scenarios in relation to which the Supreme Court in their seminal judgment and R v Waya had expressly left open the question of how the concept of proportionality should operate in the context of the confiscation regime. It prompted the Court of Appeal (Criminal Division) to conduct a comprehensive review of the authorities both before and after Waya and to lay down clear and practical guidance as to how a judge dealing with confiscation proceedings should approach the whole question of proportionality ...”
ADDED Thursday 12th November 2020
