A trustee company in liquidation, controlled by court-appointed receivers who had no part in the wrongdoing, may maintain a second limb Barnes v Addy claim against former officers without joining beneficiaries, provided the trustee can properly represent the beneficiaries' interests in the circumstances. The principles in Young v Murphy do not create inflexible rules requiring joinder whenever fraud is alleged; the question is always whether the trustee can in fact properly represent the beneficiaries. The court is entitled to look to the practical reality of who controls the trustee when making this assessment.
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