In a judgment handed down on 18 January 2012, the Court of Appeal gave guidance on the important question of whether trust documents are to be treated as being in the control of beneficiaries and former beneficiaries for the purposes of disclosure. The Court of Appeal upheld a judgment of Floyd J who had granted an application made by Paul Sinclair for disclosure of the trust documents against former beneficiaries. (North Shore Ventures Limited v Anstead Holdings Inc [2012] EWCA Civ 11).