An acknowledgement of guilt to a proceeds of crime offence on a Form 1 does not carry with it an acknowledgement that the proceeds derived from any particular crime. However, the provenance of cash may be established beyond reasonable doubt by circumstantial evidence including the scale of cultivation, sophistication of the operation, admitted supply offences, and financial evidence. The chain/cable distinction from Shepherd v The Queen applies to sentencing fact-finding, such that a particular fact need not be proved beyond reasonable doubt if it is merely a supportive strand rather than an indispensable link in the reasoning.
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