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Selected cases

Federal Court of Australia · [2026] FCA 98

Scorpion and the Frog liquidation

A Federal Court liquidation case about a corporate trustee, trust property, family law overlap and interim control of trust assets.

Federal Court of Australia13 Feb 2026

Plain-English explainers, not legal advice. Check the linked official source before you rely on a specific section, and get advice for your situation.

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Quick read

  • If a company acts as trustee, liquidation can become messy fast.
  • A Federal Court liquidation case about a corporate trustee, trust property, family law overlap and interim control of trust assets.

Use this to check

  • A company in liquidation may become bare trustee of trust assets.
  • Trust deed and appointor records are critical when control of trust property is disputed.
  • Liquidator remuneration and trust liabilities can materially affect the asset pool.

Decision snapshot

  1. 1

    What happened

    • The Scorpion and the Frog Pty Ltd was in liquidation.
    • The company had acted as trustee of the Number Stations trust, which held properties in New South Wales and Victoria.
    • Once the company went into liquidation, it ceased to hold office as trustee and became bare trustee of the trust assets.
    • The liquidator sought directions and receiver-style powers concerning the trust property.
  2. 2

    What the court had to decide

    • The Federal Court had to decide whether a trust beneficiary should be allowed to intervene, whether the proceeding should be transferred because of related family law property proceedings, and what interim restraint should apply to the liquidator's steps concerning trust assets.
  3. 3

    What the court decided

    • The Court gave Ms Collazo leave to intervene and ordered the liquidator to take no further step in the liquidation concerning the Number Stations trust assets, other than steps required to preserve the assets, pending further order.
    • The transfer question was left to be managed with the related proceedings.

Practical impact

Practical read

  • If a company acts as trustee, liquidation can become messy fast.
  • Trust deeds, appointment powers, asset records and family or beneficiary disputes should be clear before a liquidator has to work out who controls the trust property.

Useful next steps

  • A company in liquidation may become bare trustee of trust assets.
  • Trust deed and appointor records are critical when control of trust property is disputed.
  • Liquidator remuneration and trust liabilities can materially affect the asset pool.
  • Family law, trust and corporate insolvency issues can overlap in the same assets.
  • Businesses using corporate trustees should keep trust records separate and complete.

Practical read

This case is a good example of why trust structures need boring paperwork. A company acted as trustee of a family-related trust that held property. When the company went into liquidation, the liquidator needed to know what power he had over the trust assets. At the same time, a beneficiary said the trust property was tied up with family law property proceedings and should not be dealt with separately.

The Court allowed Ms Collazo to intervene and ordered the liquidator to take no further step in respect of the trust assets, except what was required to preserve them, pending further order. That was a practical holding pattern. It recognised that the trust assets, liabilities, trustee position and family law proceeding were connected enough that the liquidator should not simply press ahead with dealing with the assets.

For small businesses, the lesson is direct. Many businesses use corporate trustees for family trusts, unit trusts or trading trusts. If the company trustee becomes insolvent, the business needs the trust deed, trustee appointment history, asset register, beneficiary records and indemnity position ready. Without that, legal fees can chew up value while everyone fights about who can deal with the assets.

Checks to run

Key points

  • Keep signed trust deeds, variations and appointor records in one accessible place.
  • List which assets are company assets and which are trust assets.
  • Review trustee-removal clauses and insolvency triggers before a company gets into distress.
  • Record related-party loans, property use and beneficiary interests clearly.
  • If the trustee company is insolvent, get advice before selling or refinancing trust assets.

Key takeaways

  • A company in liquidation may become bare trustee of trust assets.
  • Trust deed and appointor records are critical when control of trust property is disputed.
  • Liquidator remuneration and trust liabilities can materially affect the asset pool.
  • Family law, trust and corporate insolvency issues can overlap in the same assets.
  • Businesses using corporate trustees should keep trust records separate and complete.

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