Under the Criminal Assets Recovery Act 1990 (NSW), a proceeds assessment order under s 27 is not to be reduced by the value of property forfeited under an assets forfeiture order under s 22. The two orders operate independently, and the word 'value' in s 27(1) does not import any authority to deduct forfeited property values. NSW is the only Australian jurisdiction that does not make express provision for adjusting proceeds assessment orders by reference to forfeiture orders; the absence of such a provision is a matter for Parliament, not judicial construction.
The full text is available to signed-in members, including the 17 later cases that cite this judgment.
7 of the 17 citing cases carry a classified treatment. How each court treated it is available to signed-in members.