Various procedural erros and delays had occured in the production of court orders in confiscation proceedings , this included an error with regard ot what was pronounced in open Court but the Court concluded that :
41. Section 174 of the Criminal Justice Act 2003 stipulates that sentences shall be pronounced in open court. The fact that by oversight or error a sentence or order is not pronounced in open court (as appears to be the case here) may be "a failure of good practice" as explained by Green J in R v. Billington  EWCA Crim 618 , does render the sentence or order a nullity.
42. It is axiomatic that not every administrative or procedural breach renders every sentence or order a nullity (see R v Guraj (2017) 1 WLR 22 at paragraphs 14, 16 and 22; R v Johal  EWCA Crim 647 ; R v T  EWCA Crim 2703 ). It is only if the administrative or procedural breach would give rise to real prejudice or unfairness.