“On 29 April 2009 the House of Lords confirmed that the prosecution are entitled in confiscation proceedings (i) to prove that the defendant had committed offences other than those to which he had pleaded or in respect of which he had been convicted and (ii) to invite the court to estimate the profit that he must have made from those offences: R. v. Briggs-Price [2009] UKHL 19.”
The Bar Council, 8th May 2009
Source: www.barcouncil.org.uk