As stated in the case of Armitage v Nurse [1997] EWCA
Civ 1279, a fundamental concept to any trust is an irreducible core
of obligations owed by the trustees to the beneficiaries. In order
to enforce these obligations, beneficiaries require a certain
amount of information from the trustees. The offshore Courts
continue to follow the Schmidt v Rosewood Trust Limited
[2003] UKPC 26 approach in exercising their inherent supervisory
jurisdiction over the disclosure of information.
In Schmidt v Rosewood Trust Limited it was considered,
"that the more principled and correct approach is to regard
the right to seek disclosure of documents as one aspect of the
court's inherent jurisdiction to supervise, and if necessary to
intervene in, the administration of trusts. The right to seek the
court's intervention does not depend on entitlement to a fixed
and transmissible beneficial interest. The object of a discretion
(including a mere power) may also be entitled to protection
