Where a beneficiary's own intervening act (here, a deed poll authorising release of funds) is the operative cause of loss, a trustee's earlier breach of trust in failing to obtain proper security does not give rise to equitable compensation. A second breach of trust that is merely consequential on an earlier breach does not enlarge the beneficiary's rights. The distinction between fiduciary duty breaches and breaches of the duty of care by trustees affects the measure of equitable compensation: the former attracts restitutionary assessment while the latter is assessed by analogy with common law damages.
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