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.