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Williams v Central Bank of Nigeria

On 19 February 2014, the Supreme Court gave judgment in the case of Williams v Central Bank of Nigeria. The issue in the case was whether s21(1)(a) of the UK Limitation Act 1980 disapplies the statutory limitation period in respect of claims by a beneficiary under a trust against an accessory (a knowing recipient of trust property or a dishonest assistant) to a fraudulent breach of trust.

In particular, the court looked at the issue of whether a stranger to a trust who dishonestly assists in a breach of trust, or knowingly receives trust property paid out in breach of trust, is a ‘trustee’ within the meaning of s21(1)(a).

Lord Sumption (with whom Lords Neuberger and Lord Hughes agreed) held that the act is concerned only with actions against ‘true’ trustees, and a stranger to a trust (although he may have dishonestly assisted the true trustee or knowingly received trust property) is not himself a ‘true’ trustee and, accordingly, a claim against him is not within the scope of s21(1)(a)…

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