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On 19 February 2014, the Supreme Court gave judgment in the case of Williams v Central Bank of Nigeria. The issue in the case was whether s21(1)(a) of the UK Limitation Act, 1980 (“the Act”) disapplies the statutory limitation period in respect of claims by a beneficiary under a trust against an accessory (a knowing recipient of trust property or a dishonest assistant) to a fraudulent breach of trust. In particular, the Court looked at the issue of whether a stranger to a trust who dishonestly assists in a breach of trust, or knowingly receives trust property paid out in breach of trust, is a “trustee” within the meaning of s21(1)(a).
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Williams v Central Bank of Nigeria  UKSC 10