An executor de son tort is not a 'trustee' or 'personal representative' for the purposes of the unlimited limitation period under s 21(1)(b) of the Limitation Act 1980 (UK), and accordingly claims against an executor de son tort for trust property are subject to ordinary limitation periods. When evaluating circumstantial evidence of gifts of chattels inter vivos, a court must consider the cumulative effect of the whole of the evidence and not assess each item of evidence in isolation.
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