Principles for protector removal: Bernheim v Krummenacher and ors [2025]GRC060

The recent decision of the Royal Court of Guernsey in Bernheim v Krummenacher provides guidance on the Court’s jurisdiction to remove protectors and the circumstances under which intervention may be justified. The case arose out of a dispute between the sole beneficiary of a substantial Guernsey trust and certain of its protectors, who resisted a restructuring of the trust’s investment management arrangements in which they had a personal interest. The Court ordered the protectors’ removal and made several adverse findings against them. This article examines the decision, including the facts of the case, the guiding principles for the removal of fiduciary office-holders, and key takeaways for practitioners.