When will the court order disclosure of a trust document to a discretionary beneficiary?

In Schmidt v. Rosewood Trust Ltd., [2003] 2 A.C. 709, some guidance is offered on this subject by Lord Walker at pp. 91 and 96 to 97: “Their Lordships consider that the more principled and correct approach is to regard the right to seek disclosure of trust documents as one aspect of the court’s inherent jurisdiction to supervise , and if necessary to intervene in, the administration of trusts. The right to seek the court’s intervention does not depend on entitlement to a fixed and transmissible beneficial interest. The object of a discretion (including a mere power) may also be entitled to protection from a court of equity, although the circumstances in which he may seek protection, and the nature of the protection he may expect to obtain, will depend on the court’s discretion. . . . However the recent cases also confirm...that no beneficiary (and least of all a discretionary beneficiary) has any entitlement as of right to disclosure of anything which plausibly can be described as a trust document. Especially when there are issues as to personal or commercial confidentiality, the court may have to balance the competing interest of different beneficiaries, the trustees themselves and third parties. Disclosure may have to be limited and safeguards may have to be put in place. The evaluation of the claims of a beneficiary (and especially of a discretionary object) may be an important part of the balancing exercise which the court has to perform on the materials placed before it. In many cases the court may have no difficulty in concluding that an applicant with no more than a theoretical possibility of benefit ought not to be granted any relief.”