Snell's Equity 35th ed: 1st Supplement

This first supplement to the 35th edition takes account of a number of major decisions, including a run of cases in the Supreme Court that have developed equitable principles in important directions. These include:

• Rukhadze v Recovery Partners GP Ltd [2025] 2 WLR 529 on the causation element of fiduciary accountability for profits
• Stevens v Hotel Portfolio II UK Ltd [2025] 3 WLR 29 on the liabilities of dishonest assistants in breaches of fiduciary duties
• Hopcraft v Close Brothers Ltd [2025] 3 WLR 423 on the circumstances in which fiduciary relations arise in commercial situations outside established categories and on the remedies for bribery
• Waller-Edwards v One Savings Bank plc [2025] 2 WLR 1263 on whether a creditor would be put on equity so as to engage the “Etridge protocol” in a hybrid case where a couple sought a loan partly for their joint benefit and partly for one partner’s sole benefit
• LA Micro Group Inc v LA Micro Group (UK) Ltd [2025] 2 WLR 1 on whether an oral agreement to transfer a shareholding was ineffective for want of formalities under s 53(1)(c) of the Law of Property Act 1925.

In relation to the powers of trustees, the supplement addresses two significant new decisions, being that of the Judicial Committee of the Privy Council in Dawson-Damer v Grampian Trust Co Ltd [2025] 1 WLR 3530, interpreting Pitt v Holt [2013] 2 AC 108 and explaining what Lord Walker meant by a breach of fiduciary duty; and that of the Court of Appeal in FS Capital Ltd v Adams [2025] EWCA Civ 53, on the consequences of violation of the improper purpose rule. On the appointment of receivers in support of foreign insolvency proceedings, the supplement mentions Kireeva v Bedzhamov [2025] AC 812, and in relation to the taking of accounts it covers Hubbard v Hubbard [2025] EWHC 855 (Ch).