Forensic accountant evidence analysing unexplained cash transactions and asset growth is admissible as expert opinion evidence where the methodology is based on specialised accounting knowledge, the assumptions and criteria are made explicit, and the jury is able to assess the conclusions for itself. Such evidence is distinguishable from the situation in Strawhorn where betterment evidence was the sole evidence of the offence. Section 67(1)(c) of the Confiscation Act 1997 (Vic) operates so that the temporal phrase identifies the property to be scrutinised, not the period during which the increase in value must have occurred; accordingly, increases in value occurring after the period of offending are captured.
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