In re Peacock (Secretary of State for the Home Dept intervening): [2012] UKSC 5; [2012] WLR (D) 42
“Where a compensation order had been made against a convicted drug trafficker under the Drug Trafficking Act 1994 (which applied where the relevant conviction was before 24 March 2003) to recover an amount equal to his benefit from that criminal activity, but the actual amount of the order was for a lesser sum as being his only realisable assets at the time of conviction, the court could later increase the amount of the order under section 16 of the Act to take account of assets he had legitimately acquired after release from prison.”
WLR Daily, 22nd February 2012
Source: www.iclr.co.uk