Regina v Jawad [2013] EWCA Crim 644; [2013] WLR (D) 209
“There was no mandatory duty to take the confiscation order made under the Proceeds of Crime Act 2002 into account when deciding on a compensation order, but the question of compensation might have been relevant to disproportion, if compensation meant that money restored to the loser would have been counted again in the confiscation order, so it was necessary to consider both issues together.”
WLR Daily, 3rd May 2013
Source: www.iclr.co.uk