R (on the application of Shahid) v Birmingham Magistrates' Court  EWHC 2969 (Admin), BPIR (forthcoming)
S had been convicted of cheating the public revenue and a confiscation order was made against him, despite his having been made bankrupt. After being committed to prison for default, S obtained a certificate of inadequacy, stating that he had no further assets which could be used to satisfy the confiscation order.
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