Can a beneficiary force an estate trustee to formally pass accounts in court even if the trustee refuses?

Yes. A beneficiary who can't get satisfactory information from an estate trustee informally can apply to the Superior Court to compel a formal passing of accounts, and the trustee's own reluctance isn't a defence to that application. Beneficiaries have a right to know how estate assets have been managed, and the court can order the trustee to prepare and file a full accounting even where the trustee insists an informal summary should be enough.

This step is usually taken after informal requests have failed — a beneficiary who has asked reasonably for records and been ignored, stalled, or given incomplete answers is in a strong position to bring this kind of application. Once ordered, the trustee must produce the same detailed accounting used in any passing of accounts: receipts, disbursements, remaining assets, and the compensation being claimed, all supported by records. A trustee who continues to resist after being ordered to account risks real consequences, including cost penalties against them personally.

Because bringing this kind of application involves its own procedure and cost exposure, beneficiaries considering it are better off documenting their earlier requests and getting advice on timing before filing, so the application is framed properly from the start.