Ratio Decidendi
A trustee must not profit from their position of trust. Where a trustee takes a renewal of a lease that they hold on trust, the renewed lease is held on the same trust, even if the landlord had refused to renew the lease for the benefit of the beneficiary. The rule is strict and inflexible to prevent trustees from being tempted to act in their own interest.
তথ্য
Sandford was trustee of a lease of Romford Market for the benefit of an infant (Keech). Before the lease expired, Sandford applied to the landlord for a renewal on behalf of the infant beneficiary. The landlord refused to renew for the infant. Sandford then took the renewal of the lease in his own name and for his own benefit, arguing that the landlord would not have granted it for the trust.
রায়ের সারসংক্ষেপ
Lord King LC held that the renewed lease must be held on trust for the infant. Even though the landlord had refused to grant the lease for the beneficiary's benefit, the trustee could not be permitted to profit from his position. The rule was to be applied strictly: if a trustee could obtain a lease renewal for his own benefit that he could not obtain for the beneficiary, 'a trustee should rather let [the lease] run out than take it himself'.
মূল উদ্ধৃতি
"I must consider this as a trust for the infant; for I very well see, if a trustee, on the refusal to renew, might have a lease to himself, few trust estates would be renewed to cestui que use."
— Lord King LC
পরবর্তী ব্যবহার
Consistently followed as the foundational authority on the self-dealing rule and the no-profit principle for fiduciaries.
The principle has been extended to all fiduciary relationships — company directors, partners, agents, and solicitors — not just trustees (Boardman v Phipps [1967]).