ABSTRACT
The article explores trustees’ fiduciary duties, focusing on the Singapore Court of Appeal’s decision in Ivanishvili v Credit Suisse Trust Ltd. Whilst trustee fiduciary duties can traditionally be seen as proscriptive (for example the no-conflict and no-profit rules), the case argues that trustees must also take steps to actively safeguard trust assets and act in good faith, even where anti-Bartlett clauses limit intervention as these cannot extend to failing to act on known fraud. By applying, in part, an objective standard of dishonesty, the case challenges narrow interpretations of trustees’ fiduciary duties and arguably expands the ‘irreducible core’ of trusteeship.
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Toby Graham and George Budd, Bullion in an unlocked room: an expansion of the irreducible core?, Trusts & Trustees. Published: 30 October 2025.
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