A liquidator of a trustee company that was trustee of multiple trusts cannot claim a lien or charge over the assets of all trusts indiscriminately; the liquidator must establish the connection between fees and expenses and the administration of each particular trust, and must apportion costs between trusts. Service of a statutory demand claiming a debt that is not yet due and payable does not constitute misleading or deceptive conduct under s 12DA of the ASIC Act where the recipient was aware of the true position and was not misled.
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