A claim for equitable compensation for fraudulent breach of fiduciary duty by a company director attracts a six-year limitation period by analogy with the tort of deceit, not the twelve-year period applicable to fraudulent breach of trust, where the director did not hold trust property. The period during which a company is in receivership may be excluded from the limitation calculation by analogy with the disability provisions of the Limitation Act 1969 (NSW). Fraud in the underlying transaction giving rise to a transfer of Torrens title land does not constitute fraud in the registration process for the purposes of s 118(1)(d) of the Real Property Act 1900 (NSW).
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