Criminal Law  /  [2026] EWHC 2430 (Admin)

Criminal Law · The Administrative Court (King's Bench Division)

H v I

Court The Administrative Court (King's Bench Division)Date 7 August 2026Citation [2026] EWHC 2430 (Admin)Source Find Case LawAlso filed under Administrative / Public Law

Checked against the judgment on 22 September 2026 · how we verify

Facts

The National Crime Agency (NCA) is conducting a wide-ranging civil recovery investigation into money laundering and illegal gambling in the Far East. On 12 August 2025 Ellenbogen J made a disclosure order under section 357 of POCA against the respondent to that order, who is anonymised in these proceedings. Two disclosure notices were later issued under it. The application to the court had been supported by a witness statement from Ms Fragassi. It described the investigation and explained why the respondent needed to be involved. It also identified specified property, making clear that the list was not exhaustive, and confirmed that this property was subject to a civil recovery investigation. The respondent then applied to discharge the order and both notices. The application also sought interim relief, which became moot once the parties agreed that the substantive application should be decided at once. The respondent advanced four grounds. First, the order authorised any appropriate officer rather than an identified officer or limited class. Second, it failed to comply with section 357(3)(b) of POCA. Third, it described the investigation too vaguely. Fourth, it was a disproportionate interference with her rights under article 8 of the European Convention. An unopposed anonymity order was also sought.

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