Beneficiary Principle Cases

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Re Abbott Fund Trusts [1900] 2 Ch 326

Facts: A trust fund was created to provide for two deaf and dumb elderly sisters who lacked the means to support themselves

Held: The trust was not held valid for the sisters’ absolute benefit, but rather as a trust for the purpose of providing for the sisters; that purpose trust was held valid because there were individuals (i.e. the sisters), as in Re Denley, who were directly and tangibly benefitting from the purpose’s performance

Re Astor’s Settlement Trusts [1952] Ch 534

Facts: Money was settled to a trustee for various purposes, including maintaining cooperation between nations and preserving the independence and integrity of newspapers

Held: The trust was held not to fall under any of the three categories, so the trust was therefore void

Re Shaw’s Will Trust [1957] 1 WLR 729

Facts: Shaw left money on trust for the creation of a 40 letter alphabet.

Held: The purpose was held not to fall under any of the three categories, so the trust was therefore void and the money reverted on resulting trust

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