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The Court of Appeal held that, as a matter of principle, a receiver appointed under the Criminal Justice Act 1988 was entitled to rely upon his lien to recover remuneration, costs and expenses incurred after the discharge of receivership. Further, having regard to the manner in which the proceedings were conducted before the High Court judge at an earlier hearing to determine the extent to which the receiver should be entitled to remuneration, expenses and disbursements (upon which an interim payment was ordered pending detailed assessment) it was not appropriate for the point now to be taken.
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