More Clues as to the Nature of the Remedy for Breach of Trust : Creggy v Barnett [2016] EWCA Civ 1004; [2017] P.N.L.R. 4

This note examines the nature of the remedy for the breach of trust that is the inadvertent paying away of trust property without authority, addressing the Target Holdings debate. The case of Creggy v Barnett, considering the rule that the acknowledgement of a debt and indeed a breach of trust can reset the limitation clock, sheds some light on the remedy. This note considers its origins as a restitutionary measure and, in line with other developments, argues its future is compensatory