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 :

R v Westbrook;R v Richardson [2020] EWCA Crim 1243 – Procedural Errors do not render a Judges Decision pronounced in open court invalid
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 [2017] 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 [2013] EWCA Crim 647 ; R v T [2010] EWCA Crim 2703 ). It is only if the administrative or procedural breach would give rise to real prejudice or unfairness.