In Air Canada v. M & L Travel Ltd., 1993 CanLII 33 (SCC), [1993] 3 S.C.R. 787; (1993), 108 D.L.R. (4th) 592 (S.C.C.), Mr. Justice Iacobucci, for the majority, said this, at p.607-8 (D.L.R.), under the heading "General Principles": Second, strangers to the trust can also be personally liable for breach of trust if they knowingly participate in a breach of trust. . . . [T]here were traditionally therefore two ways in which a stranger to the trust could be held personally liable to the beneficiaries as a participant in a breach of trust: as one in receipt and chargeable with trust property and as one who knowingly assisted in a dishonest and fraudulent design on the part of the trustees. The former category of constructive trusteeship has been termed "knowing receipt" or "knowing receipt and dealing", while the latter category has been termed "knowing assistance". (my emphasis)
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