It was seen in Chapter 18 above that, where a person receives property misappropriated from a trust, the recipient (unless a bona fide purchaser for value without notice) will be obliged to return the property or its proceeds as soon as he becomes aware of the position. This liability to a proprietary claim arises even if the recipient had no notice, actual or constructive, of the breach of trust because they were an innocent volunteer, having no duty to ‘look a gift horse in the mouth’.