Examines case law on the court's exercise of the discretion under the Trustee Act 1925 s.61 to relieve conveyancing solicitors of breach of trust liability after they have unknowingly forwarded a client's monies to a fraudster. Comments on a trend, exemplified by the Court of Appeal judgment in Santander UK v RA Legal Solicitors, of including a causation analysis in this decision-making. Discusses why the reasonableness criterion is problematic