Retired trustee's liability for post-retirement breach of trust

I have come across some STEP notes that suggest that "a retired trustee may be responsible for a breach of trust that occurs after he has retired, if he retired anticipating the breach and specifically to try to avoid involvement in the breach’.

Unfortunately, I have been unable to find any authority for this. Have members of this forum come across any case references or commentaries that may point me in the right direction?

Hauke Harrack

Lewin on Trusts (19th Edition) @ 14-63, et seq

Paul Saunders

1 Like

Halsbury’s Laws (5th ed) vol 98 para 334 which cites inter alia Webster v Le Hunt (1861)

Eddie Bell
McMillan Williams