Stein v Jaffe [2025] EWHC 2334 (Ch) (19 September 2025)

Stein v Jaffe [2025] EWHC 2334 (Ch) (19 September 2025)

The court found that, on the balance of probabilities, there was no sufficient objective manifestation of intention by Mr Anisimov to create an express bare trust over the USD2 million payment for Mr Stein's benefit. The evidence did not establish the requisite certainty of intention or that Mr Jaffe was constituted as trustee. Accordingly, no trust arose and Mr Jaffe owed no fiduciary duties to Mr Stein in respect of the payment.

Citation
[2025] EWHC 2334 (Ch)
Parties
Claimant: Kirill Ace Stein; Defendant: Eugene Jaffe
Jurisdiction
England and Wales
Judgment Date
19 September 2025
Procedural Posture
Civil / Trial Judgment
Outcome
Claim dismissed
Legal Topics
Express Trusts, Bare Trusts, Breach of Trust, Equitable Compensation, Fiduciary Duties
Equity and Trusts Commercial Law Express Trusts Bare Trusts Breach of Trust Equitable Compensation Fiduciary Duties

Case Brief

Summary, issues, holding and outcome

More case intelligence is available

Unlock the full research layer for this judgment.

Full judgment text Downloadable case file Legal principles 4 Authorities cited 14 Party arguments 2 Amounts and remedies 3
Sign in to unlock

Parties

Kirill Ace Stein

Claimant

Eugene Jaffe

Defendant

Procedural Posture

Civil / Trial Judgment

Legal Issues

  1. 1 Whether an express bare trust was created over the USD2 million payment for the benefit of Mr Stein with Mr Jaffe as trustee
  2. 2 Whether Mr Jaffe breached any duties as trustee by failing to account for or pay the sum to Mr Stein

Ratio Decidendi

The court found that, on the balance of probabilities, there was no sufficient objective manifestation of intention by Mr Anisimov to create an express bare trust over the USD2 million payment for Mr Stein's benefit. The evidence did not establish the requisite certainty of intention or that Mr Jaffe was constituted as trustee. Accordingly, no trust arose and Mr Jaffe owed no fiduciary duties to Mr Stein in respect of the payment.

Court Disposition

Claim dismissed

Orders

  • Claim dismissed in full
  • No order for equitable compensation or account of profits