The strict causation standard applicable to trustees of traditional trusts — whether the loss would have occurred but for the breach — applies equally to a company director who disposes of company property for an improper purpose. In such cases, the concept of novus actus interveniens has no role to play, and the court does not examine the relative importance of contributory causes. Causation analysis for breach of fiduciary duty differs from that applicable to common law or statutory causes of action, and a finding on causation under one regime is not determinative of causation under another.
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