from the CAB. The limits of the legislation are uncertain and accordingly, the Proceeds of Crime Act 1996 and 2005 has been subject to academic review. Writing in 2014, one academic concluded: Others conclude that civil forfeiture and recovery is a potent crime fighting device: Civil forfeiture holds with the view that it is not enough to prosecute the perpetrator but recognises the importance of also combatting the driving forces behind the criminal act. The Supreme Court, however, in reviewing the Proceeds of Crime Act 1996 concluded: Similar legislation in England and Wales has also withstood constitutional scrutiny in its highest courts. In 2014, the Supreme Court of India addressed the issue of whether forfeiture of property violated Article 20 of the Constitution of India. In deciding that forfeiture did not violate the constitution, the Indian Supreme Court cited with approval the Irish High Court decision in Gilligan v Criminal Assets Bureau. It noted that non-conviction based asset forfeiture model was also to be found in various countries: United States of America, Italy, Ireland, South Africa, UK, Australia and certain provinces of Canada. Similar civil forfeiture legislation was found to be constitutional compliant in Bulgaria. Ad Hoc Legal Aid The Department of Justice operated the CAB Ad Hoc Legal Aid Scheme until 2014. However, from 1 January 2014 the remit for the administration of the Scheme transferred to the Legal Aid Board. The scheme is applicable to persons who are respondents and/or defendants in any court proceedings brought by, or in the name of, the CAB or its Chief Bureau Officer or any member of the CAB, including court proceedings under the Proceeds of Crime Act 1996, Revenue Acts or Social Welfare Acts. The scheme also includes: social welfare appeals made to the Circuit Court under Section 34 of the Social Welfare Act 1997; tax appeals made to the Circuit Court under the Taxes Acts where the CAB or its Chief Bureau Officer or any member of the CAB is the respondent and/or defendant; and applications made by the Director of Public Prosecutions under Section 39 of the Criminal Justice Act 1994 The Ad Hoc Legal Aid Scheme provides that the grant of legal aid, including the level of legal representation and/or witness expenses allowed, is a matter for the court with the appropriate jurisdiction to deal with the specific case. The calculation of fees which apply to counsel representing