Criminal law – Appeal. The judge had erred in not taking into account R v Waya ([2013] 1 All ER 889) when considering whether it was just to make an order under s 22 of the Proceeds of Crime Act 2002 in relation to assets principally derived from mortgage fraud. Accordingly, the Court of Appeal, Criminal Division, allowed the defendant's appeal to the extent that the benefit figure under a confiscation order that had been made in 2009 was reduced from £575,000 to £198,000, albeit on that basis that the prosecution was invited to revisit a confiscation order made in 2017.