Layna represented a defendant from whom the Crown sought over half a million pounds in Confiscation proceedings.

Layna argued that the Crown had failed to discharge their evidential burden in relation to the statutory assumptions (which is a very low burden) and that the second statutory assumption had been incorrectly applied. The prosecutor had to conceded both points. Ultimately a Confiscation Order was made in the sum of £87,000, even though the defendant had assets exceeding this sum.