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Principles for protector removal: Bernheim v Krummenacher and ors [2025]GRC060

Insight

11/05/2026

  • Guernsey
Principles for protector removal: Bernheim v Krummenacher and ors [2025]GRC060

The recent decision of the Royal Court of Guernsey in Bernheim v Krummenacher provides guidance on the Court’s jurisdiction to remove protectors and the circumstances under which intervention may be justified.

The case arose out of a dispute between the sole beneficiary of a substantial Guernsey trust and certain of its protectors, who resisted a restructuring of the trust’s investment management arrangements in which they had a personal interest. 

The Court ordered the protectors’ removal and made several adverse findings against them.

This article by Cerisse Fisher and Charles Brewin in Trusts & Trustees examines the decision, including the facts of the case, the guiding principles for the removal of fiduciary office-holders, and key takeaways for practitioners.

Read the full article here.