SERIOUS ORGANISED CRIME AGENCY v AZAM

[2013] Lloyd's Rep FC Plus 53

COURT OF APPEAL (CIVIL DIVISION)

Before Lord Justice Lloyd, Lord Justice Moore-Bick, and Lord Justice McFarlane

Civil recovery - Property freezing order - Variation of property freezing order to allow payment of legal expenses - Whether court could be satisfied that the respondent had other property from which he could meet legal expenses - Burden of proof - Inference that the respondent had substantial undisclosed resources - Proceeds of Crime Act 2002, sections 233(1), 245A and 245C - Civil Recovery Proceedings Practice Direction, para 5B.1