R v Pedersen - [1995] 2 NZLR 386

Criminal law — Forfeiture — Proceeds of crime — Calculation of pecuniary penalty — Meaning of "benefits" in relation to pecuniary penalty order — Assessing gains from criminal activity — No regard to be had to principles relating to lawful commercial operations — Proceeds of Crime Act 1991, ss 24, 25, 27 and 82.