The level of knowledge required for accessorial liability for inducing or procuring an innocent breach of trust under the Eaves v Hickson principle is knowledge of circumstances which would indicate the relevant facts to an honest and reasonable person — the same standard as for knowing assistance in a dishonest breach of trust under the second limb of Barnes v Addy. 'Knowingly induced' and 'immediately procured' are not alternative bases for liability requiring different levels of knowledge. On a remitter from the Court of Appeal, findings of fact made by the original trial judge are not binding on the remitter judge but may be taken into account.
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