Quity & Trusts LawBribes and Secret Profits

Title:
Evaluate the arguments for and against making the recipients of bribes and secret profits liable to their principals under a proprietary rather than a merely personal claim. You should answer this question by reference to the arguments of at least one academic article or case note which is in favour of the recipients of bribes and secret commissions being subject to proprietary liability, and another which is against it. (You should make sure that your discussion takes account of the RECENT developments in the case law).