The contrary view is that knowing receipt is, or ought to be, part of a broader doctrine of ignorance triggering a claim for unjust enrichment.
On this view, anyone who receives property that was given away in breach of trust has a strict duty to repay the value, unless they have committed a wrong, or have changed their position after the receipt.
In Belmont Finance Corp Ltd v Williams Furniture (No 2) it was held that fraud and dishonesty was not required, i.e. negligence would suffice.
In El Ajou v Dollar Land Holdings plc[3] it was held that constructive knowledge was sufficient; Though in Polly Peck International Plc v Nadir (Asil) (No.2) [1992],[4] Scott LJ agreed that courts are always reluctant to extend constructive notice doctrine to circumstances when money is paid in the ordinary course of business.
The Court of Appeal confirmed in Byers v Saudi National Bank [2022] EWCA Civ 43 that in order to sustain a claim in knowing receipt against a third party, then the claimants must have had a beneficial interest in the property at some point when it was in the defendant's hands and they had knowledge of the breach of trust.