In Spread Trustees v Hutcheson [2011] 071 PBLR, a Guernsey case, the Privy Council has addressed the question of whether, under English law, it is permissible for a trustee exoneration clause in a trust deed, to exclude liability for acts of gross negligence. In a 3:2 decision, the board reconfirmed the principal in the Court of Appeals' decision in Armitage v Nurse [1998] Ch 241 that all liability could be excluded except for liability for dishonest and fraudulent acts. We will cover the decision in detail in due course.