Proceeds of crime – Confiscation order – Benefit from general criminal conduct – Available amount. High Court of Justiciary: In a case in which the Crown sought a confiscation order in respect of a convicted drug dealer, the court rejected all of the respondent's challenges to the Crown's calculation of the amount of his benefit from his general criminal conduct, held that a flat of which he was the heritable proprietor was free property of his and that its value fell to be included in the available amount of £126,000 proposed by the Crown, and made a confiscation order in that sum.