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Chief Constable of Merseyside Police v Owens [2012] EWHC 1515 (Admin) – Ss 19 and 22 PACE - s 1(1) PPA.

1) s 22(1) PACE did not entitle the police to retain property, seized under s 19 of PACE, once retention could no longer be justified by the purposes for which it had been seized.
2) the court could refuse to order the return of property to its owner if established that would indirectly encourage or assist a person in his criminal act.

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