This duty to account is an aspect of trust administration. As noted in Schmidt v. Rosewood Trust Limited, [2003] UKPC 26, [2003] 3 All E.R. 76, at para. 66, in the context of access to trust documents: Their Lordships have already indicated their view that a beneficiary’s right to seek disclosure of trust documents, although sometimes not inappropriately described as a proprietary right, is best approached as one aspect of the court’s inherent jurisdiction to supervise (and where appropriate intervene in) the administration of trusts. ...
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