Sentence – Confiscation order. The Administrative Court dismissed the claimant's application for a certificate of inadequacy, pursuant to s 17 of the Drug Trafficking Act 1994, with respect to a confiscation order of £2,340,017.40 against him. The claimant had taken no steps to establish that the realisable property was inadequate to meet the confiscation order and his argument concerning his interests in a French property could not avail him.