Sanam (formerly Kalsoom Amir) v National Crime Agency (formerly the Serious Organised Crime Agency)

Proceeds of crime – Civil recovery of proceeds of unlawful conduct. The Court of Appeal, Civil Division, dismissed the appeal of S against a civil recovery order made in respect of two properties. It held, among other things, that there was no proper basis for concluding that, on the facts, a recovery order in respect of the properties would violate S's rights under art 1 of the First Protocol to the European Convention on Human Rights. Such an order would not be disproportionate to the legislative aim and would not produce an unfair balance between the general interest of the community and the protection of S's fundamental rights or cast on her an excessive burden.

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