Assistance under the second limb of Barnes v Addy requires a causal connection between the stranger's conduct and the fiduciary's breach — the use of a bank account as a conduit for funds does not constitute 'assistance' of the breach that procured the funds where the breach was induced by false representations to a third party, not by the movement of funds through the stranger's account. Where the stranger's only alleged acts of assistance completely coincide with its receipt of trust property, the appropriate basis of liability is the first limb (knowing receipt), not the second limb (dishonest assistance). A bankrupt defendant may be permitted to participate in proceedings at the court's discretion, even though the bankrupt has no locus standi as of right, where serious allegations of personal misconduct must be established against the bankrupt to succeed against another defendant.
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