R v Montila [2004] UKHL 50.
- statutory interpretation.
- proceeds of crime.
1) side notes or headings in an enactment, in common with explanatory notes, are an admissible aid to construction but carry less weight than the actual text.
2) it is for P to prove proceeds of drug trafficking under s 49 DTA or criminal conduct under s 93C CJA had its origin in such activities. But position different under POCA where "criminal property" is defined in terms of D's benefit.
undefined: unpaid