Jersey Law Review | What is a trust jurisdiction clause?


The Jersey Law Review - October 2003

WHAT IS A TRUST JURISDICTION CLAUSE?

Paul Matthews

“ ‘Will you walk into my parlour?’ said a spider to a fly.”

Howitt, The Spider and the Fly

Introduction

1       Without jurisdiction, a legal system is nothing.  So detailed rules setting out when and in what circumstances the court may - or must - adjudicate on a dispute are of the first importance.  But they are even more so in an offshore financial centre like Jersey, where Islanders manage money or other assets belonging to non-Islanders.  That management often occurs through a trust arrangement.  Increasingly today in the offshore trust world, trust instruments contain clauses purporting to confer jurisdiction – or exclusive jurisdiction – to decide disputes arising out of the trusts upon the courts of a particular territory which would or might not otherwise have such jurisdiction.  The precise legal effects of such clauses are debatable, though the Jersey Royal Court has been one of the first courts actually to have to deal with them.[1] This note offers a few observations on this point, but for the most part treats of a logically anterior question, however.  This is, What in fact amounts to a (trust) jurisdiction clause?  This question arose in the decision of the Jersey Court of Appeal in Koonmen v Bender.[2]

2       The facts in that case were complex, and a number of distinct legal issues arose.  Moreover, and as is usual in such cases, the case was argued and decided on the basis of assumed facts, since no trial or other fact finding had yet taken place.  So far as concerns the scope of this note, the case can be boiled down to this.  A trust was settled by a Cayman company, of which “the moving force” was said[3] to be the first defendant (formerly a US citizen and now a Grenadan, but resident in Costa Rica).  The plaintiff’s case was that this trust held the profits of a hedge fund business carried on by himself and the first defendant.  The trust instrument was executed in January 2000, and was expressed to be governed by the law of Anguilla.  Although it was in form a discretionary trust, but with elements of what is known by US advisers as a ‘rabbi’ trust,[4] the plaintiff claimed a fixed beneficial interest in it.  Disputes arose between the plaintiff and the first defendant in relation to the trust and the beneficial interests.  The plaintiff brought proceedings in Jersey by Order of Justice against the first defendant and seven others for a declaration as to the form of the trust and his rights in relation to it, breach of trust, an account, rectification and other relief. 

4       Of those seven others, the fifth defendant was the Cayman company which was named in the trust instrument as settlor of the trust, and the eighth defendant was an Anguillan company which was the trustee originally named in the trust instrument.  The third defendant was a Jersey resident financial adviser, employed by the fourth defendant, a Jersey trust company, which was alleged to control the second defendant, another Anguillan company which was the current trustee of the trust.  The third and fourth defendants could be, and were, served in Jersey.  The plaintiff obtained leave to serve the first, second, fifth, seventh and eighth defendants out of the jurisdiction (the position of the sixth defendant is not made clear in the judgment).

5       The second and the seventh defendants applied to set aside the service upon them out of Jersey.  The third and fourth defendants applied to stay the proceedings on the grounds of forum non conveniens. The first defendant supported this application.  He had originally sought to make a similar application himself, but because of procedural defects he withdrew it, and was thereafter treated as having submitted to the jurisdiction, although still having the right to seek a stay.  The fifth, sixth and eighth defendants made no applications.  The Royal Court dismissed both these applications on 27 June 2002, and the relevant defendants appealed to the Court of Appeal.

6       In considering the applications of the second and seventh defendants to set aside service, the Court of Appeal first of all observed that the Royal Court had jurisdiction under its own rules to deal with the case because property subject to the trust was alleged to be within the Bailiwick of Jersey.[5]  But the plaintiff still had to satisfy the court (i) that there was a serious issue to be tried, and (ii) that Jersey was clearly the most convenient forum for the resolution of the issues.  For reasons not material here, the Court of Appeal concentrated on the latter of those two points.  This question was one of discretion, and therefore the Court of Appeal could only interfere on limited grounds, one of which being that the Royal Court failed to take into account matters which it should have taken into account. 

7       This note will not review in detail the Court of Appeal’s judgment on what was essentially an exercise of discretion.  Instead it concentrates on just one aspect of the decision, which the Court of Appeal considered critical, and which led ultimately to the reversal of the decision of the Royal Court.  That is the relevance of three clauses in the trust instrument which were argued to amount to a jurisdiction clause, and exclusive at that, providing that the Court of Anguilla should have jurisdiction to determine disputes arising out of the trust.

The clauses in question

8       The clauses (so far as relevant) read as follows:

"1.  Interpretation

(k) ‘The Proper Law’ means the law to the exclusive jurisdiction of which the rights of all parties and the construction and effect of each and every provision of this Settlement shall from time to time be subject and by which such rights, construction and effect shall be construed and regulated.

2.  Proper Law

This settlement is established under the laws of Anguilla and subject and without prejudice to any transfer of the administration of the trusts hereof to any change in the Proper Law and to any change in the law of interpretation of this settlement duly made according to the powers and provisions hereinafter declared the Proper Law shall be the law of Anguilla which said Island shall be the forum for the administration thereof.

14.  Power to change Proper Law

(1)  The trustees may at any time during the trust period by deed declare that:

(a)  this settlement shall from the date of such declaration take effect in accordance with the law of some other state or territory in any part of the world (being a place under the law of which trusts are recognised and enforced); and

(b)  The forum for the administration thereof shall thenceforth be the courts of that state or territory.

(2)  As from the date of any such declaration the law of the state or territory named therein shall be the law applicable to this settlement and the courts thereof shall be the forum for the administration thereof but subject to any further exercise by the trustees of the power contained in sub-clause (1) hereof”.

The concept of a trust jurisdiction clause

9       The first thing to note is that the idea of a jurisdiction clause in a trust instrument is a strange one.  Jurisdiction clauses are essentially contractual.  The parties to a transaction agree that, if a dispute arises out of their transaction, they will submit their dispute to such and such a tribunal (which might be a court, but could be an arbitration).[6]  The international jurisdiction rules of common law states usually accord a special place for agreed jurisdiction in respect of disputes arising out of contracts.[7]   Civil law countries (where the maxim “la convention fait la loi des parties" is often applied)[8] also accept jurisdiction where the parties have so agreed, at least in international cases, though not confining this to cases of disputes arising out of contracts.[9]

10     But, and contrary to the often instinctive reaction of civil lawyers, a trust is not a contract.[10]  It is not even a contract for the benefit of third parties (long permitted in civil law systems).[11]  Moreover, even to the extent that there is in the broad sense “agreement" between settlor and trustee, any such agreement is irrelevant where the claim is being brought against the trustee by the beneficiaries.  This is because, except in rare cases, they are not parties to the trust instrument and have not agreed anything, let alone on the question where any disputes will be resolved.  For this reason jurisdiction clauses do not have a long history in trust law.  You will not find them in English trusts until late in the twentieth century, and even then they are rare.  Their precise juridical nature is unclear, and their legal effect even less so.  There is little case law[12] or academic writing[13] on the subject. 

11     However, the civilian mistake of seeing the trust as a contract has led to specific provisions in the Brussels and Lugano Conventions on Jurisdiction and Judgments,[14] and now the Council Regulation (EC)[15] on the same subject.  These provisions confer exclusive jurisdiction on the courts of a state so selected by a jurisdiction clause in a trust “in any proceedings brought against a settlor, trustee or beneficiary, if relations between those persons or their rights or obligations under the trust are involved".[16] (The reference to proceedings against the settlor – the supposed “contracting party” - simply reinforces the view that civilian misunderstanding of the nature of the trust, and of the non existent role of the settlor after the trust has been created,[17] led to those provisions.)

12     So it is clear that jurisdiction clauses may be inserted into trust instruments, even if their effect is not yet clearly worked out.  The question arising in this case was simply this:  Was there a jurisdiction clause or not in this trust instrument?  The Royal Court said that there was not.  It said:

"We take it as axiomatic that clear words are required to create an exclusive jurisdiction provision in a trust deed.  The words relied on by counsel … are far from clear.  The only reference to exclusivity is found in the definition of the proper law.  The definition is not a model of good drafting.  It is difficult to know what is meant by ‘the exclusive jurisdiction’ of ‘the law’.  We note that the expert evidence of … an Anguillan barrister does not assert that the passages relied on by counsel … confer exclusive jurisdiction, but only that they make ‘the Court of Anguilla the forum of choice’.  We cannot interpret that definition, even when read with clauses 2 and 14, as conferring exclusive jurisdiction upon the Courts of Anguilla”.[18]

The Court of Appeal’s view

13     The Court of Appeal disagreed.  First of all, it denied the existence of any such principle of clear words being required to create an exclusive jurisdiction clause in a trust deed.[19] Next, it relied on the reference to “exclusive jurisdiction” of the proper law in clause 1 and the reference to the “forum for administration” of a trust in clause 2 (and also clause 14) as amounting to a provision conferring jurisdiction on Anguillan courts for the resolution of disputes.[20]  Thirdly, the Court of Appeal held that there was no meaningful distinction between the idea of exclusive jurisdiction and the notion of forum of choice (an expression not found in the trust instrument, but coming from the expert evidence referred to).  The Court of Appeal further relied on Dicey & Morris on the Conflict of Laws, in a passage dealing with contractual jurisdiction clauses.[21]

14     The Court of Appeal then said this:

"Unlike an arbitration clause, which now by statute must in most cases be respected, the courts still retain a discretion to override an express choice of forum in a contract or trust deed.  But prima facie, the court’s function is to interpret and apply the agreement of the parties or the expressed intention of those creating the trust deed, and as a general rule, the courts will give effect to a choice of forum.  The court will override an agreed choice of forum only in exceptional circumstances.  The rule is clearly stated in Dicey & Morris in rule 32(2) and in the following text and the cases thereafter cited.  Although it may be argued that the presumption in applying the express provisions of a trust deed may not be as strong as that in favour of holding parties to a contract to the terms of their agreement, I see no reason why the presumption should not be just as strong as between the settlor and those claiming to have been ‘standing behind’ the settlor as Mr Koonmen and Mr Bender were in this case and the trustees.  Further, I consider that, as an important element in the structure of the trust in respect of which any would be beneficiary claims an interest, it should prima facie be binding on such beneficiary.[22]

15     For the avoidance of doubt, I should make clear that rule 32(2) of Dicey & Morris (and the following text), referred to in that quotation, refers to a contract providing for exclusive jurisdiction to be conferred on the courts of one particular territory.  Despite the terms of the quotation, trusts do not feature in rule 32(2) at all.

Criticism of the Court of Appeal’s view

16     The Court of Appeal’s views are, however, and with very great respect, open to question.  The decision depends on the interpretation of documents from a field of practice of which, as it turns out, none of the three members of the court had any significant known experience.  That is, trust law, and in particular in the drafting of trust instruments.  The only reasoned judgment, with which the other members of the court simply agreed, was written by Kenneth Rokison QC, who was (until his retirement in 1997 from the English bar) one of the top shipping and arbitration barristers practising in London, and who continues to sit as an arbitrator, as well as in the Courts of Appeal of Jersey and Guernsey.  It is therefore unsurprising that (on this point) it draws heavily on the law and practice of jurisdiction and arbitration clauses contained in shipping and other commercial agreements.  At no point is there any reference to authorities on, or the practice of, trust law.

17     With great respect, the Court of Appeal appears to be making the mistake of treating the trust as if it were a contract, just as the Supreme Court of the Bahamas did in the case of Roywest Trust Corp (Bahamas) Limited v Savannah NV[23] in relation to a trustee exoneration clause.  In that case the court simply applied the English House of Lords’ decision of Photo Productions Limited v Securicor Limited,[24] which was a case on the effect of an exoneration clause contained in a contract.  This error emerges most clearly from the passage just cited from the judgment of the Court of Appeal.  This is couched in the language of an agreed choice of forum, and is buttressed by the references to Dicey & Morris, which are references to passages dealing exclusively with contractual jurisdiction clauses.  It also recalls the unsuccessful argument put forward in the earlier Jersey authority dealing with trustee jurisdiction clauses, EMM Capricorn Trustees Limited v Compass Trustees Limited, where the Royal Court said -

"[Counsel] argued that an exclusive jurisdiction clause in a trust deed should be given the same weight as in a contract.  But that is to ignore the difference between the two documents.  If A and B agree in a contract that they will refer any dispute to the courts of a particular country, one can well understand why they should generally be held to their bargain.  They have agreed it; why should one of them then be allowed to go back on what has been freely agreed?  But the position is very different in relation to a trust.  The exclusive jurisdiction provision of a trust deed will have been agreed only between the settlor and the original trustee.  Actions in relation to the trust may be brought by beneficiaries who were never parties to the trust deed; indeed they may not even have been alive at the time of its execution.  The policy considerations which lead to a party to a contract being held to his choice of exclusive jurisdiction cannot apply to a beneficiary who played no part in the choice of exclusive jurisdiction made in the trust deed”.[25]

18     But there is more.  Let us deal with the various points made by the Court of Appeal in turn. 

(1) Is there a principle that clear words are required to create an exclusive jurisdiction provision in a trust deed?

19     At first instance the Royal Court treated this as “axiomatic”.  But no authority was cited and I have been unable to find any.  Perhaps all that the court meant to do was to infer a general principle of construction from all the circumstances.  Those circumstances include, first, the comparative rarity of such clauses in trust instruments (certainly compared to contracts), secondly, the obscurity of their legal basis and effect, and thirdly the existing imperative rules of international jurisdiction which, with few exceptions (such as the international conventions and council regulation of the European Union),[26] do not take account of such clauses in trust deeds.[27]  The inference from these facts would be that settlors would not likely be treated as having sought to do something unusual and possibly nugatory anyway.  It would then be no more than saying "Why construe a clause as (a) trying to do something unusual and possibly lacking in effect, rather than as (b) trying to do something common and effective (i.e. selecting a proper law)?”  The latter is more likely than the former to be the settlor’s intention.  So if (unusually) the settlor intends the former, let him make clear that that is indeed his intention.  This is an intuitive process, but such processes play an important part in judicial reasoning in the common law tradition.  As Lord Hoffmann said recently (albeit in a different context) -

"[S]ome things are inherently more likely than others.  It would need more cogent evidence to satisfy one that the creature seen walking in Regent’s Park was more likely than not to have been a lioness than to be satisfied to the same standard of probability that it was an Alsatian”.[28]

(2)  The references to “exclusive jurisdiction” in clause 1 and “forum for administration” in clause 2

20     The Court of Appeal thought that, if the reference to “exclusive jurisdiction” in clause 1 did not refer “to the jurisdiction of the relevant forum or court, it would be redundant.” With respect, this is not so.  Clauses using the wording found in clause 1 have been used by trusts draftsmen, for many years, to indicate the law to which reference is to be made – and exclusively to be made – to ascertain the effects of the trust and the rights of the parties involved.  The “jurisdiction” referred to is not (as a litigation or arbitration lawyer might think) the jurisdiction or competence of the forum, but instead (as a non contentious trusts draftsman would have considered) the jurisdiction, meaning “scope” or “province of application”, of the law itself.  It answers the question, Which law governs what aspects of the trust? And the answer given here is, all aspects of this trust, including the rights of the parties, are subject to the law identified as the proper law. If the judges of the Court of Appeal had had any serious acquaintance with the drafting of trust instruments, they must have known this.

21     Secondly, the Court of Appeal thought that the reference to the forum for the administration of the trust in clause 2 (even though headed “Proper Law”, which must surely have been seen as a clue) confirmed the interpretation of clause 1 as an exclusive jurisdiction clause.  Again, this cannot be right.  The “forum for administration” of a trust is a quite different concept from an exclusive jurisdiction for the resolution of disputes (whether arising from trusts or otherwise).  The administration referred to here is not intended to include contentious breach of trust litigation.  On the contrary, it is concerned with aspects of the administration of the trust which, for one reason or another, require the assistance of the court. These might well include trustees seeking to clarify the true construction of the trust terms (for example whether they might invest in such and such an investment), or trustees seeking a direction as to whether they might safely distribute assets when there are contingent claims from third parties still in the air,[29] whether they should disclose trust documents or information to beneficiaries,[30] or whether they should take or defend legal action against third parties (so called “Beddoe"[31] applications).  Indeed, it might even involve an application to remove a trustee from office and appoint another.[32]  This is the “domestic jurisdiction” of the Chancery Court, which under the old Rules of the Supreme Court 1965 in England was represented by the provisions of Order 85.  The predecessor[33] of that Order itself was introduced in order to avoid the need in every case to have a full action to administer the trust – a so-called “administration action”.[34]  This jurisdiction – usually, but not invariably,[35] invoked by the trustees – continues today in England.[36]  A similar jurisdiction exists in Jersey[37] and, for that matter, in Guernsey.[38]

22     Hence, the phrase “forum for administration” referred directly back to the nineteenth century (and earlier) idea of the court which would take on the administration of the trust if need be.[39]  The most usual forum[40] for that, of course, was the forum of the proper law.[41]  So strictly there was no need to state the forum for administration.  And it is doubtful that selecting a different forum from that of the proper law could require the trustees to seek directions only from the nominated court.  But such an administration action was in effect procedural rather than substantive.[42]   It was a means of dealing with matters of administration and construction.[43]  It was not – could not be – used to deal with breach of trust issues,[44] characteristic of the kind of hostile trust litigation for which an exclusive jurisdiction clause might be needed. So there could not be any suggestion that this “forum for administration” was automatically intended also to be the exclusive jurisdiction for the resolution of contentious disputes involving beneficiaries.  As the leading cases in England show, that was an entirely different question, resolved – in the days before the adoption of forum non conveniens as a part of English law – by a straightforward application of the ordinary rules of national jurisdiction.  In England and other common law countries this depended initially on where the defendants were to be physically found,[45] and a similar rule was originally applied in Jersey.[46]  Thus it mattered who the defendants were.  They might or might not have been the trustees, but the important point to notice is that it is the plaintiffs who would have had to make that decision, and they would probably not have been the trustees.  Accordingly, the use of the phrase “forum for administration” could not, with respect, support the interpretation placed on clause 1 by the Court of Appeal. 

(3) No meaningful distinction between “exclusive jurisdiction” and “forum of choice”.

23     One problem with the third point is that the terminology suddenly changes.  Where the phrase previously was “forum for administration”, it has become “forum of choice”.  This is the result of the evidence of the expert on Anguillan law, who used the latter phrase, probably without intending it to mean anything different. But the Court of Appeal then says that there is no meaningful distinction between “exclusive jurisdiction” and “forum of choice”.  If “forum of choice” means “forum of administration”, then I respectfully disagree, for the reasons already given.  But if “forum of choice” means (as the Court of Appeal appear to think it means) a place which is to have jurisdiction to hear disputes, then of course the Court of Appeal is right to say there is no real distinction.  But in my view that is not what the expert meant in the context.

Other matters

24     One point which the Court of Appeal did not consider – on their view of the matter, could not have considered – is whether the claims being made in the litigation were the kinds of claim that could have been made in an administration action in any case.  If they were, then (perhaps paradoxically) the Court of Appeal would have been right to rely on the “forum for administration” clause.  If this had simply been a question about the true construction of the words used, in advance of action taken by the trustees, it would probably have been a matter of administration, and could have been the subject of an action for administration (or, in England, an application under what used to be RSC Order 85 and is now CPR Part 64).  But in fact this was a highly contentious dispute between persons claiming to be beneficiaries as to their respective rights, and in any event other claims were also made, including claims for breach of trust and fiduciary duty, which could not have been the subject of such an action.

25     There is a final matter to mention.  The Court of Appeal, after relying on the contractually based authorities that they cite, specifically refer to the fact that, in any event, they consider this case to be “contractual” in nature.  This is because they regard the plaintiff and the first defendant as having been “standing behind” the settlor, and the settlor (after all) did enter into the transaction with the original trustee.[47] So whether in strict law a trust is a contract or not, they think it is right to decide this case according to the contractual principle, because in substance the dispute arises out of an agreement.

26     There are three points to make here.  The first is a simple point of fact.  The plaintiff’s case was that he did not ‘stand behind’ the settlor, although the first defendant may have done so.[48]  So the court’s whole point here rests on an unproven and unadmitted assertion.  The court had no basis  (e.g. an admission) on which to assume that assertion to be a fact for the purposes of this application.

27     Secondly, it is odd to rely on a contract between the plaintiff and the first defendant to justify setting aside service or declaring that Jersey was a forum non conveniens on the applications of the second and seventh defendants (in the one case) and the third and fourth defendants (in the other) when none of these was a party to the trust instrument concerned.  No doubt the first defendant and the eighth defendant (original trustee) could take advantage of any relevant contract in the trust instrument, but neither of these was making the application, and it is hard to see why the other defendants should be entitled to do so.[49]

28     The third point is that the wording used in the clauses in this case is very common in offshore trust instruments, in Jersey and elsewhere.  If the Court of Appeal were intending to rely for their decision on the fact that in this particular case the parties involved in the litigation were in some way bound by an agreement between themselves, and they were not therefore relying generally on there being some kind of exclusive jurisdiction clause in the trust instrument itself which  automatically bound beneficiaries, then they should have made this clear.  Instead, they did the opposite.  The judge giving the leading judgment said:

"I consider that, as an important element in the structure of the trust in respect of which any would be beneficiary claims any interest, it should prima facie be binding on such beneficiary”.[50]

29     The judge did not however explain how such a clause could possibly be binding.  After all, in the normal case, as explained by the Royal Court in EMM Capricorn Trustees Limited,[51] the beneficiary does not agree to any such thing.  In the contractual context, a jurisdiction clause is binding on the parties only to the extent of an agreement by them that it should be so, and this is as much French law[52] as it is English.[53]  If a trust jurisdiction clause were binding without agreement, then the contractual principle would be redundant.

30     Professor David Hayton suggests that the settlor in entering a trust “agreement” with the trustee as to jurisdiction could expressly contract also “on behalf of” the beneficiaries.[54]  To the extent that they are in existence and ascertained persons, and are competent to bind themselves, this is perfectly possible, though since settlors of trusts do not normally purport to act as agents it would – as Professor Hayton says[55] – need clear language to achieve this.  There is no such clear language in the trust instrument in the present case.  But the real problem is that a person cannot – in English law, at least – contract as agent for a person not yet ascertained or in existence,[56] or for a minor[57] or a mentally disordered person.[58]  And in the case of most non-commercial trusts, especially discretionary trusts, this will exclude nearly all of the beneficiaries.  So it is not much use in practice.

31     Cohen and Staff[59] build on the agency idea by suggesting that under English arbitration law a trust beneficiary will be bound by an arbitration clause in a trust instrument, because the beneficiary is within the statutory definition of a party to an arbitration agreement, as a person “claiming under or through a party to the agreement”.[60]  As it happens, Jersey has recent legislation based on the English statute, and (on this point) to the same effect.[61]  So if the conclusion were correct in English law, it would also be correct in Jersey law.  But it would only extend to arbitration clauses, and not to court jurisdiction clauses.  And in any event, the conclusion is not correct.  The phrase “under or through” may perhaps include cases of pure agency,[62] in which case it suffers from the problems already mentioned, but it is surely mainly intended to refer to the case of transmission – whether voluntary or involuntary – of pre-existing rights.[63]  However, a trust beneficiary does not claim in any relevant sense as the assignee from the settlor of any pre-existing rights.  The beneficiary is not the assignee of the settlor’s right to sue for breach of trust or otherwise to compel due administration of the trust, because the settlor never had any such rights that he could transmit to the beneficiary by assignment.[64]  Instead the beneficiary acquires his own original rights to do so as from the date of his becoming a beneficiary. 

32     Professor Hayton, however, has a further argument.  He goes on to suggest that a beneficiary not otherwise bound becomes a party to an express jurisdiction “agreement” in a trust instrument, and will become bound by it, if he takes a benefit under that trust instrument.[65]  Now it is true that in English law there is a doctrine of so-called “benefit and burden”, whereby a person who takes a benefit under a deed is sometimes said to be obliged to take the burden of obligations purportedly imposed by it.[66]  I have found no trace of a similar general doctrine in Jersey law, although there do exist apparently exceptional rules of Jersey succession law[67] and company law[68] which in their particular contexts produce a similar effect.  But even in England it seems that this doctrine at most gives the person concerned a choice whether to perform: if the obligation is not performed, the benefit may be withdrawn.[69]  It is a “stick and carrot” arrangement.  It does not make that person personally liable for the obligation in question.[70]  And it is clear law in England that (except in the special case of a “simple” trust[71]) a beneficiary under a trust is not personally liable (say) to the trustee to reimburse his proper expenditure or pay his stipulated remuneration, where the trust assets are otherwise insufficient for the purpose.[72]  I have found nothing to suggest that Jersey trust law is different on this point.[73]

Conclusion

33     There are perhaps two lessons to be learned from this case.  The first is that trusts draftsmen  the world over must revisit their precedents and decide, in the light of this case, whether to make any amendments.  In particular, they may decide to suppress the use of the words “exclusive jurisdiction” if they appear in what is otherwise a definition of the proper law.  Secondly, they may wish either to omit reference to the “forum for administration”, or at least make clear exactly what it is intended to refer to.  Thirdly, they should consider whether they wish to insert an exclusive jurisdiction clause for the resolution of disputes.  Obviously these points matter most to anyone using a Jersey law trust, because (until overruled) the decision of the Court of Appeal is binding on the Royal Court.[74]  However, since you can never tell how much influence a case like this will have on the courts of other offshore jurisdictions, common sense suggests that all offshore trust precedents should be reconsidered. 

34     The second lesson is this.  Years ago the Jersey Court of Appeal boasted such Chancery luminaries as Mr Nicolas Browne-Wilkinson QC, Mr Leonard Hoffmann QC and Mr John Chadwick QC amongst its members. Ironically, in those days very little trust litigation reached the Court of Appeal.  Not so today.  And, of late, the number of Chancery members of the court seems to have fallen.  I think there is now only one ordinary member (out of eleven) that English Chancery lawyers would recognise as having significant Chancery expertise, and perhaps one other who has at least some.  Neither of them sat on this appeal.  Given the importance to Jersey of its trust business, and the importance to any business of having an effective legal system to vindicate the rights conferred by that business, it is surely desirable that the Court of Appeal should be in a position to muster judges with the appropriate background and experience.  No doubt there are formidable logistical and other difficulties in listing trust law appeals before Chancery specialists, especially since most of the appeals to the Court of Appeal relate to criminal law matters.  And it is true that this is neither a new nor a purely insular complaint.  The same point has been made (several times) in the past in relation to the English Court of Appeal.[75]  In that jurisdiction, some improvement has been noted.  But, in the overall economic scale of things, trust law business matters more to Jersey than it does to England.  Accordingly, I would like to think that this note will not fall upon deaf ears.

Paul Matthews is a solicitor of the Supreme Court of England and Wales and a consultant with the firm of Withers LLP, 16 Old Bailey, London, EC4M 7EG.

 



[1] See EMM Capricorn Trustees Ltd v Compass Trustees Ltd 2001 JLR 205, R Ct.

[2] Unreported judgment [2002] JCA 218, noted at 2002 JLR N[45], on appeal from 2002 JLR 407, R Ct.  I should record here that members of my firm were involved on behalf of the plaintiff in this litigation.

[3] See 2002 JLR 407, para 3.

[4] This is a well-recognised employee remuneration vehicle in US law: see the Internal Revenue’s model rabbi trust provisions and commentary published in Revenue Procedure 92-64, 1999-33 IRB 11, 17 August 1992.

[5] Service of Process (Jersey) Rules 1994, r 7(j), coupled with the Trusts (Jersey) Law 1984, art 5(c).

[6] See e.g. Toepfer International GmbH v Cargill France SA [1998] 1 Lloyd’s Rep 379, CA; Donohue v Armco Inc [2002] 1 All ER 749, HL.

[7] See e.g. the Service of Process (Jersey) Rules 1994, r 8; Civil Procedure Rules 1998, rr 6.19(1)(b)(iii), 6.20(5)(d) (England); Rules of the High Court of Justice, Ord 6 r 2 (Isle of Man).

[8] In Jersey, see (inter alia) Donnelly v Randalls Vautier Ltd 1991 JLR 49, 57, and LC Pallot (Tarmac) Ltd v Gechena Ltd 1996 JLR 241, 252.

[9] See eg the Law of 31 May 1995, no 218, Art 4 (Italy), Cass Civ 17 déc 1985, Rev cr dr int pr 1986, 537, Cass Civ 25 nov 1986, Cass Ch Comm 10 jan 1989 (France), ZPO art 38 (Germany).

[10] See Béraudo, Les trusts anglo-saxons et le droit français, 1992, 20-23; Lupoi Trusts: a comparative study, 2000, 162-166, 374-76; Camara, Derecho Privado Europeo, 2003, 1136-53.

[11] French Code Civil, art 1121; Italian Codice Civile, arts 1411-1413; Spanish Código Civil, art 1257.

[12] Though see EMM Capricorn Trustees Ltd v Compass Trustees Ltd 2001 JLR 205, R Ct.

[13] See Cohen and Staff (1999) 7 J Int TCP 203; Hayton, in (ed Atherton) Papers of International Academy of Estates and Trust Law 2000, 11.

[14] 1968 (Brussels) and 1988 (Lugano); in the UK they were incorporated into domestic law by the Civil Jurisdiction and Judgments Acts of 1982 and 1991 respectively.   They have not so far been incorporated into Jersey (or Guernsey) law, although by virtue of ss 39 and 52(2) of the 1982 Act there is power to do so by Order in Council.

[15] No 44 of 2001 (OJL 12, 16.1.2001, p1), replacing the Brussels Convention as between EU member states other than Denmark.

[16] Article 17 (2) of each Convention, and article 23(4) of the Regulation.

[17] Maitland, Trust and Corporation, in Selected Essays, 1936, 165; Re Astor's ST [1952] Ch 534, 542; Bradshaw v University College of Wales [1988] 1 WLR 190, 194; Re Murphy's Settlements [1999] 1 WLR 282, 295; Twinsectra Ltd v Yardley [2002] 2 All ER 377, para 96.

[18] 2002 JLR 407, para 29.

[19] Unreported judgment [2002] JCA 218 at para 45.

[20] Ibid, paras 46-47.

[21] Para 12-078; in the CA judgment, para 48.

[22] Para 49.

[23] (1987) 1 BOCM 61, 80; see also Armitage v Nurse [1998] Ch 241, 254, CA.

[24] [1980] AC 827, 850, HL.

[25] EMM Capricorn Trustees Ltd v Compass Trustees Ltd 2001 JLR 205, para 16.

[26] See text to footnotes 14-16 above.

[27] Guernsey is (so far as I know) a unique exception amongst national rules: see the Trusts (Guernsey) Law 1989, s 4(b)(iii).

[28] Home Secretary v Rehman [2002] 1 All ER 122, 141; see also Aktieselskabet Dansk Skibsfinansierung v Brothers [2001] 2 BCLC 324, 329-30, CFAHK, and Sheppard v Home Secretary [2003] EWCA Civ 1921, para 10.  The choice of Regent’s Park for Lord Hoffmann’s example is perhaps unfortunate.

[29] E.g. Re Benjamin [1902] 1 Ch 723 (missing beneficiary); Re Yorke [1997] 4 All ER 907 (potential creditor); Re Sutton 1999 JLR N-19 (ditto).

[30] E.g. Re Rabaiotti 1989 Settlement 2000 JLR 173 (Jersey law and BVI law settlements); Re CA Settlement [2002] JLR 312, para 16; Schmidt v Rosewood Trust Ltd [2003] 2 WLR 1442, [2003] 3 All ER 76, para 51.

[31] Re Beddoe [1893] 1 Ch 547; Re Den Haag Trust 1995 JLR 150.

[32] See e.g. Chellaram v Chellaram [1985] Ch 409, 432-33.

[33] Ord 55 r 3 of the Rules of the Supreme Court 1883.

[34] See e.g. Re Davies (1888) 38 ChD 210; Conway v Fenton (1889) 40 ChD 512; Re Medland (1889) 41 ChD 476, 492; Ashburner’s Principles of Equity, 2nd ed 1933, 132-34.

[35] As in Chellaram v Chellaram [1985] Ch 409, 432-33 (application to remove trustees).

[36] Civil Procedure Rules 1998, Part 64; see generally Underhill and Hayton, Law of Trusts and Trustees, 16th ed 2003, 832-847.

[37] Trusts (Jersey) Law 1984, art 47; Re a Settlement 1994 JLR 139; Re Den Haag Trust 1995 JLR 150; Re Abacus (CI) Ltd 2000 JLR 165; Re S Settlement 2001 JLR N-37; Re CA Settlement 2002 JLR 312, para 16.  To the extent that the Royal Court in Compass Trustees Ltd v McBarnett 2002 JLR 321 considered that it had power under Art 47 to vary the entitlement of beneficiaries under a trust (having already concluded that Art 43, which confers power to approve such variations, did not apply in the circumstances), it is submitted that the court fell into error: varying beneficial interests is not a mere matter of administration; see also Broere v Mourant & Co (Trustees) Ltd [2003] JCA091, para 5.

[38] Trusts (Guernsey) Law 1989, ss 62, 63; see Federal Trust Co Ltd v McDonald-Smith (2001) 4 ITELR 211, 218; Dawes, Laws of Guernsey, 2003, 150-153.

[39] Hence Harman LJ’s reference in Re Weston’s Settlement [1969] 1 Ch 223, 247 to the courts of Jersey (at that date) never having “made an order executing the trusts of a settlement”.  It is also possible that in modern times some draftsmen have inserted a “forum for administration” clause in the (erroneous) belief that it would assist in demonstrating that the general administration of the trust was being carried on outside the UK for capital gains tax purposes.

[40] Though not the invariable one: see Chellaram v Chellaram [1985] Ch 409, 432-33.

[41] Hence the provision for the forum for administration to change automatically with the proper law, contained in clause 14(2).

[42] Heydon v Gell (1900) 21 NSWLR (Eq) 625; MacFarlane v Brown [1919] NZLR 218, 232-236.

[43] Once an administration order is made the court is effectively in charge of the entire administration, and the trustees ought not to exercise any powers without its sanction: see Lewin on Trusts, 17th ed 2000, para 36-80.

[44] Eg Re Weall (1889) 42 ChD 674; Dowse v Gorton [1891] AC 190, 202; Re Thorpe [1891] 2 Ch 360; Nutter v Holland [1894] 3 Ch 408. In Jersey, see Broere v Mourant & Co (Trustees) Ltd [2003] JCA091, para 5, and in Guernsey, see Federal Trust Co Ltd v McDonald-Smith (2001) 4 ITELR 211.

[45] See Ewing v Orr-Ewing (1883) 9 App Cas 34; Chellaram v Chellaram [1985] Ch 409; Webb v Webb [1991] 1 WLR 1410.

[46] See Carslund v Jacomb, Lloyds Bank Ltd à la cause (1955) 248 Ex 545, 249 Ex 405, Middle East Engineering Ltd v Edwards (1980) JJ 265.  Cf the Service of Process and Taking of Evidence Law 1960, art 2, and the Service of Process Rules 1961 (now the Service of Process Rules 1994).

[47] Text to footnote 22 above.

[48] See text to footnote 3 above.

[49] It is just conceivable that the appointment of the second defendant as successor trustee might amount also to an assignment of the “benefit” of the “contract”; but that would depend on its terms (not disclosed), and anyway the court did not rely on this.

[50] Para 49.

[51] Text to footnote 25 above.

[52] Cass Ch Comm, 10 jan 1989.

[53] Donohue v Armco Inc [2002] 1 All ER 749, HL.

[54] Loc cit, note 13 above, 18. 

[55] Ibid.

[56] Kelner v Baxter (1866) LR 2 CP 174; cf Companies Act 1985, s 36C, and the Companies (Jersey) Law 1991, art 21(1).

[57] Except in the rare cases where the minor could bind himself: G(A) vG(T) [1970] 2 QB 643, 651-2.

[58] Except for lucid intervals: Drew v Nunn (1879) 4 QBD 661.

[59] (1999) 7 J Int TCP 203.

[60] Arbitration Act 1996, s 82(2).

[61] Arbitration (Jersey) Law 1998, art 6(1).

[62] See eg Rye & Eyre v IRC [1935] AC 274, 278-79.

[63] See eg Celsteel Ltd v Alton House Holdings Ltd (No 2) [1987] 2 All ER 240, CA.

[64] See the authorities cited in n 17 above.

[65] Loc cit, 18-19.

[66] Halsall v Brizell [1957] Ch 169, 172; ER Ives Investment Ltd v High [1967] 2 QB 379.

[67] I.e. the civilian rule that an heir who accepts the succession (other than with benefit of inventory) must pay its debts: Terrien, 2nd ed 1578, 219; Coûtume Réformée, art 235; Bérault, 6th ed 1660, 249, 254; Hoüard, Dictionnaire du Droit Normand, 1780, vol II, tit Héritier, 708-709

[68] See the Companies (Jersey) Law 1991, art 21(2).

[69] Rhone v Stephens [1994] 2 AC 310, 322; Thamesmead Town Ltd v Allotey [1998] 3 EGLR 97.

[70] IDC Group Ltd v Clark [1992] 1 EGLR 187, 190, affd, [1992] 2 EGLR 184.

[71] Hardoon v Belilios [1901] AC 118, PC.  A “simple” trust is one where the property is held for a beneficiary (or beneficiaries) absolutely, so that the trustee has no function beyond holding the title to the property.  The agency solution of Prof Hayton would usually work in such a case, provided that appropriate language was used in the trust.

[72] Ibid.

[73] C.f. the Trusts (Jersey) Law 1984, art 22.

[74] Though with some exceptions: see State of Qatar v Al Thani 1999 JLR 118, 126.

[75] See e.g. (1989) 105 LQR 599, 606; (1994) 110 LQR 335, 340; (1994) 8 TLI 43, 47; [1994] RLR 44, 51.

 


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