LA Micro Group (UK) Ltd v LA Micro Group Inc [2023] EWCA Civ 214—A (sub-)trust for thee but not for me

In LA Micro Group (UK) Ltd v LA Micro Group Inc [2023] EWCA Civ 214, the Court held that under an express trust with A as trustee and B as beneficiary, a constructive sub-trust could arise with B as sub-trustee and A as beneficiary under the sub-trust, resulting in B dropping out of the picture and the legal title and beneficiary interest merging in A. It is argued that the Court’s reasoning is conceptually untenable given the inherent instability of a circular sub-trust structure; the better view is that the remedy given was a sui generis equitable order.