Va. Code » Title 64.2. Wills, Trusts, and Fiduciaries » Subtitle IV. Fiduciaries and Guardians » Part A. Fiduciaries » Chapter 12. Commissioners of Accounts
Virginia Code

Va. Code Ann. § 64.2-1213 (2026)

Effect of confirmation of report

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The report, to the extent to which it is confirmed by an order of the circuit court upon exceptions filed pursuant to subsection B of § 64.2-1212 or in whole when confirmed by lapse of time without exceptions pursuant to subsection A of § 64.2-1212, shall be taken to be correct, except so far as it may, in a suit, in proper time, be surcharged or falsified. However, no person who was a party to exceptions filed to the report shall bring a suit to surcharge or falsify the report, and in such case the action of the court on the report shall be final as to such party, except that it may be appealed from as in other suits.

Code 1919, § 5429; 1932, p. 554; 1944, p. 107; Code 1950, § 26-34; 2012, c. 614.

Notes of Decisions
Cited in 3 cases (2 in the last 5 years), 2017–2023 · leading case: Gray v. Binder, 805 S.E.2d 768 (Va. 2017).
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Gray v. Binder, 805 S.E.2d 768 (Va. 2017). · cites it 4× “Code § 64.2-1213. When exceptions are filed, the court can accept or reject the report in whole 8 or in part.”
Kishna Shirese Minor v. Anne M. Heishman Comm'r of Accounts, 892 S.E.2d 667 (Va. Ct. App. 2023). · cites it 10× “” - 12 - The Commissioner argues that the trial court’s orders entered November 8 and 10, 2021, confirming the Commissioner’s report “were final as to Minor and Liberty Mutual” based on language contained in Code § 64.2-1213. That statute provides that “[t]he report, to the…”
Phillips v. Rohrbaugh, 300 Va. 289 (2021). · cites it 2× “In addition, Code § 64.2-1213 allows for suits to surcharge or falsify a report even after it has been confirmed by the circuit court.”
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