Bartlett v Barclays Bank Trust Co [1980]

Brightman J said he did not interpret Cross J in Re Lucking [1967] as saying that the
trustee must have a nominee on the board, merely that this would be a
convenient method by which a prudent man of business may make an informed
Other methods available.
In this case Brightman J also opined that a higher
standard of diligence is expected from paid trustees such as a trust company.
[Yet in no subsequent case was this higher
professional standard applied.]