R v Varma [2012] UKSC 42; [2012] WLR (D) 270
“The Crown Court had the power and, in most cases, where the criteria in section 6 of the Proceeds of Crime Act 2002 were satisfied, the duty to make a confiscation order against a defendant following conviction for an offence in respect of which the defendant had received an absolute or a conditional discharge.”
WLR Daily, 10th October 2012
Source: www.iclr.co.uk