ABSTRACT
The decision by the Supreme Court in Rukhadze and others v Recovery Partners GP Ltd and another [2025] UKSC 10 confirms that a but-for causation is inapplicable in the context of an account of profits within fiduciary relationships, diverging from its role in equitable compensation as held by the House of Lords in Target Holdings Ltd v Redferns [1996] AC 421. This analysis explores the reasoning behind the judgment, delving into the nature of an account of profits, the requisite level of single-minded loyalty from fiduciaries, and the interplay with modern commercial norms.
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Isaac Lam, Rukhadze and others v Recovery Partners GP Ltd and another [2025] UKSC 10 – account of profits and but-for causation, Trusts & Trustees. Published: 10 May 2025.
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