9.1 The law of trusts has an important role to play in modern commercial transactions and therefore in commercial litigation. Given the increasingly transnational context of modern business, disputes over the administration of a trust or the subject matter of a trust may involve a number of different currencies. However, there has been surprisingly little focus in the English case law on foreign currency judgments in the context of the law of trusts.1 Some guidance can be found in Commonwealth jurisprudence.2 Otherwise, the applicable principles must be extracted by drawing appropriate analogies from other areas of law.