boardman v phipps criticism

Issues Did Boardman and Tom Phipps breach their duty to avoid a conflict of interest, despite the fact that the company made a profit and . The institutional subscription may not cover the content that you are trying to access. <> P0Y|',Em#tvx(7&B%@m*k They bought a majority stake. The trustees were prevented from purchasing any further shares as they were not authorised investments under the terms of . Tom Boardman was a solicitor for a family trust. Boardman had concerns about the state of Lexter & Harris' accounts and thought that, in order to protect the trust, a majority shareholding was required. It depends on the circumstances. The gist of it is that the defendant has unjustly enriched himself, and it is against conscience that he should be allowed to keep the money. With the knowledge of the trustees, Boardman and Phipps decided to purchase the shares themselves. Viscount Dilhorne and Lord Upjohn (DISSENTING): A COI only arises and renders a fiduciary liable to account for profits made where a reasonable man, looking at all the relevant circumstances, would conclude that there was a real, sensible possibility of conflict of interest, which was not the case here. Sealy, Commercial Law and Commercial Reality (London 1984), pp. A fiduciary agent has to account to for any profits acquired by reason of the his fiduciary position and the opportunity or knowledge resulting from it, even if the principals could not have made the . The articles and case notes are designed to have the widest appeal to those interested in the law - whether as practitioners, students, teachers, judges or administrators - and to provide an opportunity for them to keep abreast of new ideas and the progress of legal reform. In the present case, as the purchase of the shares was entirely out of the question, Regal Hastings was said to be inapplicable. He and a beneficiary, Tom Phipps, went to a shareholders' general meeting of the company. Some societies use Oxford Academic personal accounts to provide access to their members. Viscount Dilhorne. The Appellant Phipps was Chairman of this company and Mr. Boardman was one of its directors. Phipps v Boardman: HL 3 Nov 1966 A trustee has a duty to exploit any available opportunity for the trust. stream 2010-2023 Oxbridge Notes. Access to content on Oxford Academic is often provided through institutional subscriptions and purchases. Boardman and Phipps would have to account for their profits, despite the fact they had best intentions and made the Lexter & Harris a profit. F5aE}*?fxl1oA+;{ S>"~qOf~AcW|g[ VFaxb'o Tns34}#rPDB The trust assets include a 27% holding in a textile company called Lexter & Harris. The majority of the House of Lords (Lords Cohen, Guest and Hodson) held that there was a possibility of a conflict of interest, because the solicitor and beneficiary might have come to Boardman for advice as to the purchases of the shares. If you cannot sign in, please contact your librarian. The trust assets include a 27% holding in a textile company called Lexter & Harris. Boardman, the "It is perhaps stated most highly against trustees or directors in the celebrated speech of Lord Cranworth L.C. Grey v Grey (1677) Jamie Glister; 4. For terms and use, please refer to our Terms and Conditions The residuary estate included 8000 shares in J.ester & Harris Ltd., an underperforming private company with issued share capital of 3l),000 1 ordinary shares. Maguire v Makaronis 1997 infers that anyone under a fiduciary obligation must foreshow righteousness of their transactions. Become Premium to read the whole document. On this Wikipedia the language links are at the top of the page across from the article title. In April 1997, Mrs Newman and her husband granted a lease of 1 Vicarage . Case summary last updated at 24/02/2020 14:46 by the Lord Upjohn dissented, and held that Phipps and Boardman should not be liable because a reasonable man would not have thought there was any real sensible possibility of a conflict of interest. endobj Society member access to a journal is achieved in one of the following ways: Many societies offer single sign-on between the society website and Oxford Academic. . Boardman v Phipps (1967) was a classic illustration of the principles set out in Lord Russell's statement. Don't already have a personal account? Cambridge University Press is committed by its charter to disseminate knowledge as widely as possible across the globe. To purchase short-term access, please sign in to your personal account above. able to bring it back to profit, and the trust fund benefited. Boardman v Phipps [1967] 2 AC 46, [1966] 3 WL R 1009, [1966] 3 All ER 721. Therefore, Boardman was speculating with trust property and should be liable. <>>> Ought Boardman and Tom Phipps to be allowed remuneration for their work and skill in these negotiations? Read more about this topic: Boardman V Phipps, Judgment, A severe though not unfriendly critic of our institutions said that the cure for admiring the House of Lords was to go and look at it.Walter Bagehot (18261877), The welcome house of him my dearest guest.Where ever, ever stay, and go not thence,Till natures sad decree shall call thee hence;Flesh of thy flesh, bone of thy bone,I here, thou there, yet both but one.Anne Bradstreet (c. 16121672), You see how this House of Commons has begun to verify all the ill prophecies that were made of itlow, vulgar, meddling with everything, assuming universal competency, and flattering every base passionand sneering at everything noble refined and truly national. The plaintiff is ready to concede it, but in case the other beneficiaries are interested in the account, I think we should determine it on principle. Boardman v Phipps (1967) was an example of the application of strict liability. They owed fiduciary duties (to avoid any possibility of a conflict of interest) because they were negotiating over use of the trust's shares. All rights reserved. Unit 11. His liability to account depends on the facts. Associated Provincial Picture Houses Ltd v Wednesbury Corporation [1948] 1 KB 223. This has fuelled a more general debate as to whether the no-conflict rule should be harsh or more flexible. A personal account can be used to get email alerts, save searches, purchase content, and activate subscriptions. Such persons will, however, be entitled to payment on a liberal scale for their work and skill. Some societies use Oxford Academic personal accounts to provide access to their members. our website you agree to our privacy policy and terms. Pettitt v Pettitt (1970) and Gissing v Gissing (1971) John Mee; 22. This is a famous case in which John Phipps successfully claimed that, flowing fro. . If you believe you should have access to that content, please contact your librarian. On the 1st March, 1962, the Respondent John Anthony Phipps com- menced an action against his younger brother, Thomas Edward Phipps and Mr. T. G. Boardman, a solicitor and partner in the firm of Messrs. Phipps & . 4 0 obj Final, Pharmaceutical Calculations practice exam 1 worked answers, Acoples-storz - info de acoples storz usados en la industria agropecuaria. But when, as in this case, the agents acted openly and above board, but mistakenly, then it would be only just that they should be allowed remuneration. 39^40. The trust property included a substantial shareholding in a private company. Boardman felt that by asset-stripping the company he could increase the value of the shares. criticism, see L.S. Administrative Law. He said unequivocally that knowledge learnt by a trustee in the course of his duties is not property of the trust and may be used for his own benefit unless it is confidential information which is given to him (i) in circumstances which, regardless of his position as a trustee, would make it a breach of confidence to communicate it to anyone or (ii) in a fiduciary capacity. They owed fiduciary duties (to avoid any possibility of a conflict of interest) because they were negotiating over use of the trust's shares. . Part II describes the rationales for adopting each of the approaches to awarding allowances to dishonest fiduciaries. stream Boardman and Tom Phipps had breached their duties to avoid a conflict of interest. Q6 - You now need to carry out research about the different universities/colleges you are interested in applying to by finding the answers to the areas you have outlined in your responses to questions 3 and 5 above. Boardman v Phipps [1966] UKHL 2 is a landmark English trusts law case concerning the duty of loyalty and the duty to avoid conflicts of interest. The claim for repayment cannot, however, be allowed to extend further than the justice of the case demands. Boardman v Phipps [1967] 2 AC 46. The other two members of the majority, Lord Hodson and Lord Guest, opined that information can constitute property in appropriate circumstances and in the current case, the confidential information acquired can be properly regarded as property of the trust. principal shareholder group, Boardman obtained information about the factories of Lester & Harris in Coventry and Nuneaton and its property in Australia. The House of Lords maintained the strict rule that historically equity has imposed on a fiduciary. He also obtained detailed trading accounts of the English and Australian arms of the business. He (and a beneficiary) purchased shares in a company in which the trust already had a substantial holding. If you are a member of an institution with an active account, you may be able to access content in one of the following ways: Typically, access is provided across an institutional network to a range of IP addresses. This article explores how the dissenting judgment of Lord Upjohn in Boardman v Phipps has been preferred by the lower courts and why the courts have adopted such a position. Lecture notes, lectures 1-10 - Financial Maths for Actuarial Science, Lecture Notes - Psychology: Counseling Psychology Notes (Lecture 1), The effect of s78 Police and Criminal Evidence Act 1984 Essay, Critical Reflection on my Work Experience, 2019 MCQ 1 answers - Online Multiple Choice Questions, Caso Walmart vs Kmart - RESUMEN DEL TEMA DE LOGISTICA DE OPERACIONES - DSM-5, Syllabus in Social Science and Philosophy, ACCA FINANCIAL MANAGEMENT Pocket Notes 2021 22, Mischief Rule, Examples, Advantages, Disadvantages and rectification, Human Muscular Skeletal Systems. The majority agreed unanimously that liability to account for the profits made by virtue of a fiduciary relationship is strict and does not depend on fraud or absence of bona fides, and so Phipps and Boardman would have to account for their profits. S;70[`J)LQ,ecX_LK,*q3>~ B=eA* But then John Phipps, another beneficiary, sued for their profits, alleging a conflict of interest. See below. Another beneficiary (P) claimed conflict of interest and demanded her share of the profit, because of S fiduciary role. Therefore the agent must account to the trust for any profit made out of the position. The solicitor to a family trust (S) and one Beneficiary (B)-there were several-went to the board meeting of a company in which the trust owned shares. They wanted to invest and improve the company. Whether or not the trust or the beneficiaries in their stead could have taken advantage of the information is immaterial: p. 111A, The question whether or not there was a fiduciary relationship at the relevant time must be a question of law and the question of conflict of interest directly emerges from the facts pleaded, otherwise no question of entitlement to a profit would fall to be considered. Oxbridge Notes in-house law team. However the court exercised its inherent jurisdiction to make a monetary award to S for his services to improving the value of the trust. This meant he had to account for all profits arising out the CoI, no matter how remote the probability was that this CoI would actually arise. F5aE}*?fxl1oA+;{ S>"~qOf~AcW|g[ VFaxb'o Tns34}#rPDB students are currently browsing our notes. This species of action is an action for restitution such as Lord Wright described in the Fibrosa case. S;70[`J)LQ,ecX_LK,*q3>~ B=eA* 399, 400 (PC). 1 0 obj *Lecturer in Law at University of East London, Email: Search for other works by this author on: The Author (2008). This authentication occurs automatically, and it is not possible to sign out of an IP authenticated account. But they did not obtain the fully informed consent of all the beneficiaries. If the defendant has done valuable work in making the profit, then the court in its discretion may allow him a recompense. my lords. The majority agreed unanimously that liability to account for the profits made by virtue of a fiduciary relationship is strict and does not depend on fraud or absence of bona fides, and so Phipps and Boardman would have to account for their profits. Boardman was speculating with trust property and should be liable. Material Facts Boardman was the solicitor for a family trust. Boardman had concerns about the state of Lexter & Harris accounts and thought that, in order to protect the trust, a majority shareholding was required. 2.I or your money backCheck out our premium contract notes! xksgD2u$N+xH)%"dU &c~m_WMnny|t80^olIv"+E] mv}f"gv UY Fe_go_eu6[xGLBdUS-?b\4?s=}GO0upAQ![*`E"~ Boardman appealed against a finding that he was a constructive trustee for, or agent did not necessarily render him accountable for profit from its use, yet in, the present case, as both the information which satisfied B and P, purchase of the shares would be a good investment and the opportunity to bid, came as a result of B acting on behalf of the trustees B and P, trustees of five eighteenths of the shares in the company for the respondent and, were liable to account to him for the profit thereon accordingly, Human Rights Law Directions (Howard Davis), Tort Law Directions (Vera Bermingham; Carol Brennan), Marketing Metrics (Phillip E. Pfeifer; David J. Reibstein; Paul W. Farris; Neil T. Bendle), Public law (Mark Elliot and Robert Thomas), Commercial Law (Eric Baskind; Greg Osborne; Lee Roach), Introductory Econometrics for Finance (Chris Brooks), Criminal Law (Robert Wilson; Peter Wolstenholme Young), Principles of Anatomy and Physiology (Gerard J. Tortora; Bryan H. Derrickson), Electric Machinery Fundamentals (Chapman Stephen J. Key Points. For librarians and administrators, your personal account also provides access to institutional account management. They wanted to invest and improve the company. With the full knowledge of the trustees, Boardman and Phipps purchased a majority stake of the shares themselves. Flower; Graeme Henderson). Cambridge Journals publishes over 250 peer-reviewed academic journals across a wide range of subject areas, in print and online. The full text is available here: http://www.bailii.org/uk/cases/UKHL/1966/2.html, -- Download Boardman v Phipps [1967] 2 AC 46 as PDF --, Transvaal Lands Co v New Belgium (Transvaal) Lands & Development CO [1914] 2 Ch 488, http://www.bailii.org/uk/cases/UKHL/1966/2.html, Download Boardman v Phipps [1967] 2 AC 46 as PDF. A testator le ft 8000 shares (a minority share holding) of a private company in . Click the account icon in the top right to: Oxford Academic is home to a wide variety of products. This is because there is no possibility the trustee would seek Boardman's advice to purchase the shares and at any rate Boardman could have declined to act if given such request. %PDF-1.5 Request Permissions, Editorial Committee of the Cambridge Law Journal. trust. His lordship, with respect . Lord Upjohn also agreed with Lord Cohen that information is not property at all, although equity will restrain its transmission if it has been acquired by a breach of confidence. "And it is a rule of universal application, that no one, having such duties to discharge, shall be allowed to enter into engagements in which he has, or can have, a personal interest conflicting, or which possibly may conflict, with the interests of those whom he is bound to protect. This decision was followed and applied in Boardman v Phipps. CASE BRIEF TEMPLATE. The Cambridge Law Journal publishes articles on all aspects of law. Boardman was a solicitor to trustees of a will trust. Boardman and another trustee, Fox, therefore . Judgement for the case Boardman v Phipps The solicitor to a family trust (S) and one Beneficiary (B)-there were several-went to the board meeting of a company in which the trust owned shares. Boardman v Phipps seems like a more onerous application of rule against an unauthorised profit than that in Regal Hastings, all that is apparently required for a fiduciary to be liable is that ' a reasonable man looking at the relevant facts would think there was a real possibility of . John Phipps and another beneficiary, sued for their profits, alleging a conflict of interest by Boardman and Phipps. way. The only defence available to a person in such a fiduciary position is that he made the profits with the knowledge and assent of the trustees. (Keech v Sandford 1726) - landlord would not grant new lease to beneficiary so trustee took in his own name. Proprietary relief in Boardman v Phipps 3 the trustees, although Ethel, who suffered from senile dementia, took no active role in the trust affairs at the material time. The majority disagreed about the nature and relevance of information used by Boardman and Phipps. Published by Oxford University Press. Oxbridge Notes is operated by Kinsella Digital Services UG. If your institution is not listed or you cannot sign in to your institutions website, please contact your librarian or administrator. 25% off till end of Feb! An important feature of the journal is the Case and Comment section, in which members of the Cambridge Law Faculty and other distinguished contributors analyse recent judicial decisions, new legislation and current law reform proposals. By his Will dated the 23rd December, 1943, Mr. C. W. Phipps left an annuity to his widow and subject thereto 5/18ths of his estate to each of his sons and 3 /18ths to his daughter, Mrs. Noble. HL (majority 3-2) held that S and B would hold their acquired shares as constructive trustees for the beneficiaries. View your signed in personal account and access account management features. endobj View the institutional accounts that are providing access. Cambridge University Press (www.cambridge.org) is the publishing division of the University of Cambridge, one of the worlds leading research institutions and winner of 81 Nobel Prizes. The trustees were informed of these intentions. They suggested to Mr Fox, a trustee, that it would be desirable to acquire a majority shareholding, but Fox disagreed. ), Rang & Dale's Pharmacology (Humphrey P. Rang; James M. Ritter; Rod J. Each issue also contains an extensive section of book reviews. BOARDMAN and Another v. PHIPPS Viscount Dilhorne Lord Cohen Lord Hodson Lord Guest Lord Upjohn. This article is also available for rental through DeepDyve. fiduciary he was accountable to the beneficiaries for any profit he had made. 4 0 obj endobj His liability to account depends on the facts. I think there should be a generous remuneration allowed to the agents. Applicant VEAL of 2002 v Minister for Immigration & Multicultural & Indigenous Affairs [2003] FCA 437. Boardman was concerned about the accounts of the company, and thought that to protect the trust a majority shareholding is required. Boardman was concerned about the accounts of the company, and thought that to protect the trust a majority shareholding is required. They realised together that they could turn the company around. Tom Boardman was a solicitor for a family trust. Do not use an Oxford Academic personal account. A breach of a fiduciary duty is of strict liability, regardless of their intention Boardman v Phipps 1967 1. This article explores . ", The phrase "possibly may conflict" requires consideration. O(Grx+Q_[%Dm%|(Dy m%Cn(Dy(o%~(Jg(Q[tJD|(R(GIAK(xRph1%Z'-Y!bO-FDY b<9hHJO-F?!b<98HO-F!b-f b. P0Y|',Em#tvx(7&B%@m*k Name of Case. The Cambridge Law Journal <>>> By using Wilberforce J held that Boardman was liable to pay for his breach of the duty of loyalty by not accounting to the company for that amount of money, but that he could be paid for his services. 31334. He attended the annual general meeting of Lester &amp; Harris Ltd, a company in which the trust had a substantial shareholding. Lords Cohen, Guest and Hodson held that there was a possibility of a conflict of interest because the beneficiaries might have come to Boardman for advice as to the purchases of the shares. 1 0 obj Boardman v Phipps is a leading authority on the no-conflict rule. Lord Cohen said the information is not truly property and it does not necessarily follow that, because an agent acquired information and opportunity while acting in a fiduciary capacity, he is accountable. Nicholas Collins, The no-conflict rule: the acceptance of traditional equitable values?, Trusts & Trustees, Volume 14, Issue 4, May 2008, Pages 213224, https://doi.org/10.1093/tandt/ttn009. House of Lords. You do not currently have access to this article. Following successful sign in, you will be returned to Oxford Academic. % The trust benefited by this distribution 47,000, while Boardman and Phipps made 75,000. Mr Boardman (the trust's solicitor) investigated the affairs of the company, initially on behalf of the trust, and gained useful information. BOARDMAN v PHIPPS. The House of Lords maintained the strict rule that historically equity has imposed on a fiduciary. However, the circumstances were quite different to those in Boardman v Phipps. Boardman v Phipps is a leading authority on the no-conflict rule. 2011 Editorial Committee of the Cambridge Law Journal National Provincial Bank Ltd v Ainsworth (1965) Alison Dunn; 20. Oxbridge Notes uses cookies for login, tax evidence, digital piracy prevention, business intelligence, and advertising purposes, as explained in our Select your institution from the list provided, which will take you to your institution's website to sign in. The majority of the House of Lords (Lords Cohen, Guest and Hodson) held that there was a possibility of a conflict of interest, because the solicitor and beneficiary might have come to Boardman for advice as to the purchases of the shares. In my view it means that the reasonable man looking at the relevant facts and circumstances of the particular case would think that there was a real sensible possibility of conflict; not that you could imagine some situation arising which might, in some conceivable possibility in events not contemplated as real sensible possibilities by any reasonable person, result in a conflict.". Therefore, Boardman was speculating with trust property and should be liable. law since Boardman v Phipps. [1] The trust assets include a 27% holding in a company (a textile company with factories in Coventry, Nuneaton and in Australia through a subsidiary). Choose this option to get remote access when outside your institution. Lord Upjohn was in dissent in Boardman v. Phipps, but his dissent was "on the facts but not on the law": Queensland Mines Ltd. v. Hudson (1978) 52 A.L.J.R. It was irrelevant that S had acted in an open and honest (and profitable!) Boardman v Phipps [1967] 2 AC 46. by Will Chen; 2.I or your money back Check out our premium contract notes! endobj Penn v Lord Baltimore (1750) Paul Mitchell . If the agent has been guilty of any dishonesty or bad faith, or surreptitious dealing, he might not be allowed any remuneration or reward. %PDF-1.5 overrule Boardman v Phipps.3 It should be noted that the majority in Boardman v Phipps were all-too-aware that they were imposing a constructive trust on a person who had acted in good faith. No positive wrongdoing is proved or alleged against the appellants but they cannot escape from the consequences of their acts involving liability to the respondent unless they can prove consent.: p. 112A, I have no hesitation in coming to the conclusion that the appellants hold the Lester & Harris shares as constructive trustees and are bound to account to the respondentIn the present case the knowledge and information obtained by Boardman was obtained in the course of the fiduciary position in which he had placed himself. Priority of trustees indemnity inter se: pari passu or first in time priority? The company made a distribution of capital without reducing the values of the shares. 3 0 obj The problem was that the trust instrument itself did not allow the investment of, Boardman purporting to act on behalf of the trust (relationship of agenc, discovered the likely cost of the shares and purchased the shares in his own, At all points, Boardman had acted honestly, After Boardman had purchased the controlling interest in the company. enough, and that am attempt to take control of the company should be initiated. Paragon Finance plc v DB Thakerar & Co (a . They were therefore liable for the profits earned. Do not use an Oxford Academic personal account. Annetts v McCann (1990) 170 CLR 596. His Lordship distinguished Regal (Hastings) v Gulliver by restricting Regal Hastings to circumstances concerned with property of which the principals were contemplating a purchase. law since Boardman v Phipps. Boardman v Phipps. Register, Oxford University Press is a department of the University of Oxford. <> &Thb;ynxP\ -|tLo9sRx[8-a5& 'vd `f@). will. 'Rules of equity have to be applied to such a great diversity of circumstances that they can be stated only in the most general terms and applied with particular attention to the exact circumstances of each case. This item is part of a JSTOR Collection. His daughter, Mrs Newman, was one of the trustees. For more information, visit http://journals.cambridge.org. WI[y*UBNJ5U,`5B1F :IK6dtdj::yj It is not contended that the trustees had such knowledge or gave such consent. p. 117D G, The relevant rule for the decision of this case is the fundamental rule of equity that a person in a fiduciary capacity must not make a profit out of his trust which is part of the wider rule that a trustee must not place himself in a position where his duty and his interest may conflict.: p. 123C, Whether there is a possibility of conflict depends on whether the reasonable man looking at the relevant facts and circumstances of the particular case would think that there was a real sensible possibility of conflict: p. 124B, Note that in this case, not only did the principals, which are the trust beneficiaries, no lose anything, but they actually profited from the increase in value of shares held under the trust as a result of the actions of defendants thus it can be surmised that regardless of whether any wrongdoing or harm was caused to the principal, the fiduciary is liable for all profits acquired as a result of his position. Here you will find options to view and activate subscriptions, manage institutional settings and access options, access usage statistics, and more. 7 Boardman v. Phipps [1967] 2 A.C. 46, 124 per Lord Upjohn. Boardman and Tom Phipps, one of the beneficiaries under the trust, were unhappy with the state of the . However, they were generously remunerated for their services to the trust. He said unequivocally that knowledge learnt by a trustee in the course of his duties is not property of the trust and may be used for his own benefit unless it is confidential information which is given to him (i) in circumstances which, regardless of his position as a trustee, would make it a breach of confidence to communicate it to anyone or (ii) in a fiduciary capacity. John Phipps and another beneficiary, sued for their profits, alleging a conflict of interest by Boardman and Phipps. <>/ExtGState<>/ProcSet[/PDF/Text/ImageB/ImageC/ImageI] >>/Annots[ 17 0 R 22 0 R 23 0 R 25 0 R 35 0 R 36 0 R 40 0 R 42 0 R] /MediaBox[ 0 0 594.96 842.04] /Contents 4 0 R/Group<>/Tabs/S/StructParents 0>> Constructive trusts, unjust enrichment, tracing 2010 Cases, Written by Oxford & Cambridge prize-winning graduates, Includes copious academic commentary in summary form, Concise structure relating cases and statutes into an easy-to-remember whole. The trust benefited by this distribution 47,000, while Boardman and Phipps made 75,000. Chase Manhattan Bank v Israel-British Bank Ltd, Industrial Development Consultants v Cooley, https://en.wikipedia.org/w/index.php?title=Boardman_v_Phipps&oldid=1123060721, Creative Commons Attribution-ShareAlike License 3.0, [1965] Ch 992, [1965] 2 WLR 839 and [1964] 1 WLR 993, Viscount Dilhorne, Lord Cohen, Lord Hodson, Lord Guest and Lord Upjohn, This page was last edited on 21 November 2022, at 15:30. Boardman v Phipps (1967) Michael Bryan; 21. Lord Denning MR, Russell LJ and Pearson LJ upheld Wilberforce J's decision and held that Boardman and Phipps had breached his duty of loyalty, which arose as they had become self-appointed agents representing the trust, by putting themselves in a conflict of interest. It publishes over 2,500 books a year for distribution in more than 200 countries. The proceedings. xksgD2u$N+xH)%"dU &c~m_WMnny|t80^olIv"+E] mv}f"gv UY Fe_go_eu6[xGLBdUS-?b\4?s=}GO0upAQ![*`E"~ (eg- acting for multiple people) a. &Thb;ynxP\ -|tLo9sRx[8-a5& 'vd `f@). Lord Hodson and Lord Guest: Since S and B had used information made available to them by virtue of their relationship to the trust (as solicitor and beneficiary respectively), and since the information was trust property, they had made a profit out of trust property, rendering them liable.

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