Guernsey: High Court Dismisses Strike-Out Against Insolvent Fund Liquidators (Xenfin v GFG)

In Xenfin v GFG [2026] EWHC 2158 (Ch), the Chancery Division refused to strike out a £13 million asset-recovery action brought by liquidators of a Guernsey investment vehicle following the collapse of the Dolphin Group.

  • Low Threshold for Officeholders: The Court held that liquidators are not required to establish formal written agreements at the pleading stage where contemporaneous documentation supports an implied investment management relationship.

  • Practice Impact: Officeholders recovering misappropriated fund assets can proceed to trial on unwritten management arrangements without risk of early interlocutory strike-out.

Guernsey: High Court Dismisses Strike-Out Against Insolvent Fund Liquidators (Xenfin v GFG)
Hayden Morgan 14 September 2026
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