Vitolio v Police - [1994] 3 NZLR 210

Criminal law — Sentence — Confiscation of motor vehicle — Accused convicted of driving while disqualified and with excess breath alcohol — Sentence of four months' periodic detention and confiscation of motor vehicle — Appeal against confiscation order — Test to be applied — Whether undue hardship to accused or others — Criminal Justice Act 1985, s 84(2) and (4).