From: James Lee <james.lee@kcl.ac.uk>

Sent: Wednesday 23 July 2025 10:15

To: Enrichment - Restitution & Unjust Enrichment Legal Issues; obligations

Subject: UK Supreme Court on Remedies for Dishonest Assistance and Breach of Fiduciary Duty

 

Dear All,

 

The UK Supreme Court has given judgment in Stevens v Hotel Portfolio II UK Ltd [2025] UKSC 28 https://www.supremecourt.uk/cases/judgments/uksc-2023-0142. It is the latest in a series of judgments from the UKSC on equitable remedies, and the latest in a series of judgments from the UKSC on equitable remedies where Lord Briggs gives the lead judgment.

 

It concerned complex dealings relating to hotels near Hyde Park in London. The claimant company (which as the name suggests had a portfolio of hotels) had sold three such hotels to a company of which the sole shareholder was Mr Stevens. Mr Stevens was in fact acting in respect of the transactions as nominee for Mr Ruhan, who was a director of Hotel Portfolio II. Mr Ruhan had never disclosed his involvement to Hotel Portfolio. He used those profits to pay off existing sums which he owed in respect of other developments. Hotel Portfolio brought a claim against Mr Ruhan for breach of fiduciary duty first in not disclosing his interest in the purchaser company and second in dissipating the profits from the sale, which as a fiduciary he was holding on constructive trust. It also claimed against Mr Stevens for dishonestly assisting Mr Ruhan's breaches. There were two issues for the Court (as summarised by the appeal documents):

 

'(1) Whether a dishonest assistant can be liable in relation to a breach of a constructive trust of secret profits.

(2) The extent to which gains from one breach of fiduciary duty can be set off against losses from another connected breach.'

 

By a majority of 4 to 1, the Supreme Court allows the claimant company's appeal, and disagrees with the reasoning of the Court of Appeal that Hotel Portfolio had not suffered relevant loss. Lord Briggs gives the lead judgment, and Lord Burrows dissents. The work of various members of the ODG/RDG are cited.

 

Lord Briggs adopts the view that it is important to give effect to the institution of the constructive trust, rather than treat it as 'just a remedy'. Some extracts may give a flavour of the reasoning, which is his typical mix of pragmatism and appeals to the utility of what are thought to be general equitable principles

 

35... 'It would seem to me extraordinary and contrary to basic equitable principle for the dissipation of a fund held on an institutional constructive trust to give rise to no remedy by way of equitable compensation for any consequential loss. It is suggested that the real remedies arising from the constructive trust are proprietary. But a dissipation of the fund held upon constructive trust strikes at the heart of any proprietary remedy. The very concept of dissipation means that there is neither the fund nor any traceable proceeds of it to which a proprietary remedy can usefully attach. And the dissipation thereby causes a loss to the beneficiary which will generally be at least equivalent in value to the property dissipated, since the beneficiary was its beneficial owner, and has thereby been deprived of any proprietary claim to the property. It might be said that, strictly, the beneficiary's loss was the value of his beneficial interest in the property dissipated rather than the value of the property itself. But since it is accepted that the minimum terms of this constructive trust required Mr Ruhan to deliver or transfer the property on demand to HPII, that strikes me as a distinction without a difference, at least in the mouth of Mr Ruhan or Mr Stevens. They cannot be heard to say that, for example because they dishonestly kept secret the existence of the dividend until they had dissipated it, HPII's beneficial interest in it was of no significant value.

 

...

41. If the dishonest assistant can be liable for breach of a constructive trust then a fortiori the trustee must be liable, and the liability of both of them must include liability to compensate for loss caused to the beneficiary by the breach. Unfortunately none of those cases concerned constructive trusts of unauthorised profits made in breach of trust or (as here) of fiduciary duty, and none have been found. But the absence of specific authority cannot on its own justify treating such constructive trusts as exceptions from the generally accepted principle. There may be a number of explanations for the silence. Alleging and proving dishonesty against the assistant is itself a serious hurdle, not surmounted in any of the above cases other than Papamichael, and it may be that the trustee defendants in the secret profits cases were of sufficient substance to repay or that they had not dissipated the profits before being held to account. In many of the secret profits cases there was no dishonesty involved from start to finish, on the part of anyone.

 

42. I would therefore reject both the premise for, and the second supposed consequence of, the proposition that this type of constructive trust is, in substance, just a remedy. It is entirely inconsistent with recent judicial thinking about this constructive trust, in the bribery cases, which are just about a particular species of secret or unauthorised profit. It runs counter to the very recent decision of this court, in Rukhadze, which was about unauthorised profits. The constructive trust of profits imposes the usual obligation on the constructive trustee not to dissipate the trust property, and the usual obligation on both him, and upon any dishonest assistant in the dissipation, to compensate the beneficiary for any loss caused thereby.

...

57. I return to the issue whether the supposed fact that the constructive trust is a remedy for an earlier breach of trust, in making the profits in the first place, supports the aggregation of the two breaches (making the profit and then dissipating it) for the purposes of applying the Target but-for test. I have of course rejected the premise for this supposed outcome, but I will address the outcome nonetheless. In my judgment it does not support the aggregation of the two breaches. My main reason for that conclusion is that, if it did, then it would render the intended real effect of the constructive trust illusory, at least in depriving the beneficiary of any remedy for the loss of his beneficial interest in the trust property, against the dishonest assistant in the dissipation, and for no reason having anything to do with fairness, equity or justice.

...

59. It must be supposed that the constructive trust of an unauthorised profit is intended by equity to have some useful effect. And the function of the court is to validate rather than inhibit that effect. The intent of equity is that the beneficiary should be the owner of the unauthorised profit, because the constructive trust is a real (ie institutional) trust. The potentially valuable proprietary remedies may be rendered nugatory by dissipation of the trust property. But the constructive trust also provides a vital means of recourse for compensation for loss caused by the dissipation, against both the trustee and the dishonest assistant (i.e. one who assists in the dissipation), but only if the breach consisting of the making of the profit is not airbrushed out of the counterfactual by being aggregated with the breach consisting of its dissipation.'

 

The Supreme Court considers the exception to the no-set-off rule of gains and losses arising from breaches in Bartlett v Barclays Bank Trust Co Ltd (Nos 1 and 2) [1980] Ch 515 for the first time (at [63]ff) - they endorse the general possibility but deny that it is relevant on the facts here because it was all part of a dishonest scheme.

 

87. 'In Bartlett there were undoubtedly two transactions, both of which the bank trustee failed negligently to prevent. But they were closely connected because the trustee's involvement in them consisted in the same single continuing breach by omission, namely not preventing or stopping the directors' adoption of a foolishly risky policy. In all three cases, unlike the present, the inequity arose as between the trustees and the beneficiaries.'

 

Lord Briggs then summarises the conclusions of his judgment:

 

100. 'It may assist in the digestion of this over-long judgment if I summarise my essential conclusions of law, as follows:

  1. Like any other trust, a constructive trust of unauthorised profits gives rise to an immediate proprietary interest of the beneficiary in the fund representing those profits, from the moment of their receipt by the trustee.
  2. A dissipation of the fund by the trustee is a breach of trust for which the trustee is liable to compensate the beneficiary for the loss of its proprietary interest. That loss is generally to be assessed by reference to the value of that proprietary interest, but for the dissipation of which would still belong to the beneficiary.
  3. A person who dishonestly assists the trustee in the dissipation is jointly liable with the trustee for the loss caused by the dissipation.
  4. Those general principles are unaffected by the facts that (a) the fund held on constructive trust is or represents unauthorised profits made in an earlier breach of fiduciary duty to the same beneficiary, (b) the making of the profits caused the beneficiary no loss and (c) the effect of the constructive trust of the profits was to confer a gain on the beneficiary.
  5. Nothing in Target v Redferns or in AIB v Redler requires or suggests that, in asking what would be the beneficiary's position but for the breach of trust complained of (here the dissipation of the trust fund), the earlier breach of trust or (here) fiduciary duty consisting of the making of the profits, is also to be assumed not to have happened. On the contrary, the counterfactual required by those cases requires attention to be given to the terms of the trust which has been breached, in order to ascertain what would have been the consequences of the observance of those terms but for the breach. If no profits were made, there would be no constructive trust.
  6. Nothing in the Novoship principle (which insulates a dishonest assistant from liability to disgorge profits which he has not himself made) prevents a dishonest assistant from being jointly liable for the loss caused by a dissipation, merely because the fund which has been dissipated consisted of, or represented, unauthorised profits in the making of which the assistant also dishonestly assisted.
  7. The general equitable principle that a trustee may not set off gains against losses made or incurred by successive breaches of trust is subject to a potential exception where the disallowance of a set-off would be inequitable, but no such inequity occurs in a case where to allow the set-off would undermine the integrity and effect of the constructive trust, in particular by enabling the dishonest assistant to escape scot-free from having to compensate the beneficiary for the loss caused by the dissipation of the fund.'

 

Lord Burrows' focused dissent is grounded in a review of the literature and rigorous analysis. Again, some extracts:

 

123. 'If the question is whether the constructive trust confers a wide judicial discretion to order or grant an appropriate remedy for a cause of action (for example, for an equitable wrong or for unjust enrichment) then it is clear that that is not how the constructive trust operates in English law. In this jurisdiction, there is no such remedial constructive trust.

 

124. However, the clear rejection of that analysis of a constructive trust leaves open difficult and disputed questions as to the extent to which a constructive trust, of the type with which we are here concerned, is dependent on the choice of a claimant and/or the involvement of a court (whether by the making of an order or a declaration). But whatever view is taken on those questions, it is hard to deny that, in many situations, a constructive trust is a legal response to an equitable wrong or unjust enrichment. As counsel for both parties accepted in their oral submissions, in the context of unauthorised profits made in breach of fiduciary duty, with which we are here dealing, the constructive trust of the profits can be viewed, along with an account of profits, as a legal response to the breach of fiduciary duty. Moreover, I would add, it is an initial response that then creates the possibility of the claimant being awarded, or choosing, proprietary remedies in respect of identifiable (ie traceable) assets that are effective, and in that sense, confer priority on the defendant's insolvency.

 

125. If this type of constructive trust is operating as a response to a breach of fiduciary duty, along with an account of profits, it may be thought unnecessary to recognise that there is also an equitable compensation remedy for dissipation of the profits because that would merely replicate what would be achieved by requiring the constructive trustee to account for the profits made. That may perhaps explain why there appears to be no previous example in the case law of equitable compensation having been awarded in such a situation. And if there is no equitable compensation remedy against the constructive trustee in that situation, it follows, from the requirement of joint and several liability, that there can also be no equitable compensation remedy against the dishonest assister.

 

126. However, the important point is that, even if one accepts Mr Pickering's submission that the imposition of a constructive trust of the profits does carry with it the possibility of an equitable compensatory remedy against the constructive trustee for dissipation of those profits, it does not necessarily follow that Mr Pickering can build on it to establish that HPII has a dishonest assistance claim against Mr Stevens for equitable compensation for the loss caused by dissipation of those profits. On the contrary, there are several significant objections to accepting Mr Pickering's submissions on dishonest assistance'

 

128. A major objection to accepting Mr Pickering's submissions is that, on the facts, there was one dishonest scheme (or design or plan) which involved the fiduciary and the assister from the start. It is wholly artificial to divide it up into the acquisition of the profits and their dissipation. The scheme comprised both. Its whole purpose was for Mr Ruhan to acquire unauthorised profits that would be laundered away out of reach. The purpose of the scheme would have been completely undermined if, having made the profits, Mr Ruhan handed them across to HPII. Mr Ruhan was assisted throughout by Mr Stevens.

 

129. Applying a compensatory analysis, the correct question as regards Mr Stevens is, what position would HPII have been in if the scheme had not been carried out, that is if there had been no breach of fiduciary duty by Mr Ruhan from the start? The answer is that HPII would have been in the same position as it now is. It has suffered no overall loss. In particular, it would never have made the profits that Mr Ruhan himself made (see para 108 above) so that his profits do not represent a loss to HPII. HPII no longer has the hotels but it sold them at, what the judge held, was a fair market value. Its overall financial position has been made no worse by Mr Ruhan s and Mr Stevens' wrongdoing...

 

133. A third objection is that, along with an account of profits, a constructive trust of the profits can be viewed as a disgorgement response imposed by the law for equitable wrongdoing by the principal wrongdoer. The constructive trust is not a compensatory response and, on the facts of this case, the principal wrongdoer has, overall, caused no loss to the beneficiary. It would be inconsistent with the law's imposition of disgorgement, as against compensation, if a dishonest assister were held liable for compensation where the only possible way of formulating a loss is to view it as a failure, or frustration, of the disgorgement response...

 

136. A final objection (and very closely related to what has been said in the previous paragraph) is that Mr Pickering's submissions lead to the potential for double recovery. Indeed, Matthew Frey and Zihang Liu in their case-note on the Court of Appeal's decision 'Equitable set off, election and constructive trusts' (2024) 140 LQR 331 argue that the key to understanding why the decision was correct is that the central problem of principle faced was the need to avoid double recovery. The problem of double recovery can be starkly shown if we hypothetically amend the facts so that, instead of HPII suffering no loss from Mr Ruhan's breach of fiduciary duty, it is assumed that HPII suffered a loss of, say, £75m because, had there been no breach, it would itself have exploited the opportunity and would have made profits of £75m. If the appellant's arguments were correct, it would appear that HPII would have an equitable compensation remedy for dishonest assistance against Mr Stevens for £75m plus £102.26m. The former was the loss caused by assisting Mr Ruhan's exploitation of the opportunity and the latter was the loss caused by assisting the dissipation of the profits made by Mr Ruhan of £102.26m. If Mr Pickering's submissions were correct, it would appear that both compensatory measures could be accumulated by HPII as against Mr Stevens because they are separate and consistent in covering different losses. Yet it surely cannot be correct - and produces double recovery - if HPII were able to accumulate both measures of compensation against Mr Stevens in that way. The conventional (albeit blunt) means of avoiding any such double recovery is by recognising that a claimant cannot combine, and must elect between, equitable compensation for compensating loss and an account of profits for disgorgement of profits. Once the claimant has elected for an account of profits against the principal wrongdoer, and not equitable compensation for loss, the possibility of double recovery would be avoided if it were to be accepted that there could be no equitable compensation against either the principal wrongdoer or the dishonest assister. That would mean that, on these facts, where HPII has elected for an account of profits against Mr Ruhan, there can be no equitable compensation remedy against Mr Stevens...

 

139. The law abhors the dishonest wrongful conduct of Mr Stevens. But the temptation to distort equitable principles so as to award a substantial compensatory remedy against him, where remedies against the principal wrongdoer are thwarted (eg by insolvency) must be resisted. Moreover, it would be inaccurate to suggest that Mr Stevens escapes scot-free. Leaving aside any possible criminal sanctions, Mr Stevens is required to account for all the profits he has made from his dishonest assistance and, because of the dishonesty involved, there is no question of a dishonest assister being entitled to any equitable allowance for work and skill. That is the established and appropriate remedy against him given that HPII has suffered no overall loss.'

 

Best wishes,

Jamie

 

-

James Lee

Professor of English Law 

The Dickson Poon School of Law

Somerset House East Wing

King's College London

Strand

London WC2R 2LS

 

E-mail: james.lee@kcl.ac.uk 

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