A former trustee's equitable lien over trust assets does not confer a right to retain possession of those assets as against a new trustee. The lien survives transfer to the new trustee and is enforceable by judicial sale or appointment of a receiver, but the former trustee must transfer the assets. The former trustee is entitled to ensure the new trustee does not take steps destructive of the security interest. The observations in Re Suco Gold to the contrary should not be followed.
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