Fiduciary relationships have been found very easily in circumstances where tracing is sought: Lord Templeman in Lipkin Gorman v Karpnale Ltd approved the Australian case of Black v Freedman (1910) 12 CLR 105, where it was said that a thief holds stolen money on trust for the true owner and that the true owner may therefore trace in equity into a mixed fund. Lord Browne-Wilkinson was of the same view in Westdeutsche [1996] AC 669 at 716.
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