A receiver and manager may be appointed over trust property pursuant to s 37 of the Supreme Court Act 1986 (Vic) to secure a former corporate trustee's right of indemnity, even where no replacement trustee has been appointed, where the appointment pre-empts potential difficulties and protects trust creditors. The Court expressed obiter support for the view that a former trustee's equitable lien does not confer a right to retain trust assets against a new trustee.
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