Regina v Sumal & Sons (Properties) Ltd: [2012] EWCA Crim 1840; [2012] WLR (D) 247
“A landlord who committed an offence of managing an unlicensed house, contrary to section 95(1) of the Housing Act 2004, did not ‘obtain’ property ‘as a result of or in connection with’ his criminal conduct, for the purposes of section 76(4) of the Proceeds of Crime Act 2002, by the receipt of rent. Therefore a court sentencing a landlord for such an offence could not impose a confiscation order in the sum of the rent received.”
WLR Daily, 8th August 2012
Source: www.iclr.co.uk