Limitation of action – Period of limitation. The Supreme Court held that a stranger to a trust who was liable to account on the grounds of dishonest assistance in a breach of trust or knowing receipt of trust assets was not a trustee for the purposes of s 21(1)(a) of the Limitation Act 1980. The court further held that an action 'in respect of' any fraud or fraudulent breach of trust to which the trustee was a party or privy did not include an action against a party which was not itself a trustee.