Williams v Central Bank of Nigeria

A stranger to a trust who is liable only as a constructive trustee for dishonest assistance in a breach of trust or for knowing receipt of trust property is not a 'trustee' within s.21(1) of the Limitation Act 1980; such claims are therefore subject to the ordinary six-year limitation period (here under s.21(3)) and do not benefit from the disapplication of limitation in s.21(1)(a)-(b).