Examining Purpose Trusts, Will Trusts, and Trustee Retirement

This essay provides an in-depth analysis of purpose trusts, will trusts, and the retirement of trustees within the framework of trust law. It begins by examining non-charitable purpose trusts, their historical development, and their distinction from charitable and private trusts, referencing the Restatement of Trusts and the Uniform Trust Code. The essay then discusses the beneficiary principle and its implications for non-charitable purpose trusts, exploring exceptions such as trusts for graves, religious services, and animal care. It critiques the uncertainty and perpetuity rules, arguing for the validation of certain purpose trusts. Furthermore, the essay delves into the duties and investment powers of trustees, and the legislation governing their retirement, concluding with practical applications and legal considerations relevant to discretionary trust wills. The essay references various legal cases and statutes, including the Charities Act and the Trustee Act, to support its arguments and provide a comprehensive overview of the subject matter.

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PURPOSE TRUSTS, WILL TRUSTS, AND RETIREMENT OF TRUSTEES
Student Name
Lecturer’s Name
Course Name
Institutional Affiliation
Words; 3973 words

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Cases
Bourne v Keane [1919] A. C. 815
Cowan v Scargill [1985] ch 270
Meehan v Hurley [1930] 51 R.I. 51, 150 A. 819
Pettingall v Pettingall [1842] 11 LJ Ch 176
Re Thompson [1934] ch 342
Saunders v Vautier [1841] EWHC J82, (1841) 4 Beav 115
Speight v Gaunt [1883] UKHL 1
Re Astor Settlement Trusts v Astor V Scholfield [1952] [1952] Ch 534, [1952] 1 All ER 1067,
[1952] 1 TLR 1003

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Legislation
Charities Act 1993
Perpetuities and Accumulations Act 2009
Restatement of Trusts in 1935
Charities Act 2003
Trust Investments Act 1961
Trustee Act 1925
Trustee Act 2000

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Table of Contents
Question 1........................................................................................................................................5
Introduction......................................................................................................................................5
Summary..........................................................................................................................................5
Analysis...........................................................................................................................................6
Agree Critics....................................................................................................................................6
Graves, Monuments, and Tombstones.....................................................................................6
Religious services and mass requiems for the dead................................................................7
Trusts for taking care of animals.............................................................................................7
Disagree Critics...............................................................................................................................8
The Beneficiary Principle..........................................................................................................8
The Uncertainty Principle.........................................................................................................8
The Perpetuity Rule...................................................................................................................9
Conclusion.......................................................................................................................................9
Question 2......................................................................................................................................11
Introduction....................................................................................................................................11
Duties of trustees...........................................................................................................................12
Investment powers.........................................................................................................................13
Application....................................................................................................................................14
Conclusion.....................................................................................................................................14
Question 3......................................................................................................................................15
Discretionary trust wills.................................................................................................................15
Legislation on trustees retiring......................................................................................................15
Application....................................................................................................................................17
Bibliography..................................................................................................................................18

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Question 1
Introduction
“Non-Charitable Purpose Trusts: Past, Present, and Future”, 2016, by Richard C. Ausness
The author highlights non-charitable purpose trusts and the ways in which such trusts make it
easy for estate planners to execute the objectives of their clients successfully. The article outlines
the origin and development of non-charitable purpose trusts. It also distinguishes between,
charitable trusts, non-charitable purpose trusts, and private trusts. The author examines how non-
charitable purpose trusts were treated in England and USA before the “Restatement of Trusts in
1935” was promulgated1. The author also intended to survey how the “Uniform Trust Code” as
well as other Restatements have adopted the provisions of the non-charitable purpose trusts; it
offers advices on how the instruments of the trusts should be drafted and how the “Uniform Trust
Code” should be revised.
The beneficiary principle consists of the law of trust in England as well as other Commonwealth
nations. It operates on the policy that trusts which lack charitable features as required by
“Sections 2 and 3 of the Charities Act 2003” and also do not constitute the property trust for
beneficiaries (the defined people to benefit from the property), are invalid (void)2. The principle
prohibits the execution of trusts that do not have defined people to benefit from them
(beneficiaries) and are listed for non-charitable purposes. However, English law has in many
circumstances ruled against the beneficiary principle. This paper seeks to find out the exact trusts
that the law upholds despite the fact that they have been prohibited by the beneficiary principle.
It seeks to examine the necessity of non-charitable purpose trusts.
Summary
The article assesses the history and development of non-charitable trusts and other trusts as well.
Trusts that are designed to be used for a particular purpose instead of the usual property
distribution to defined group of people are referred to as purpose trusts. Charitable trusts are
categorized under purpose trusts since the purpose of such trusts is to “benefit some individuals
“through eradication of poverty and improving education & religion. The use in which the trusts
are intended make them purpose trusts. There is the existence of “non-charitable purpose trusts”
1 Restatement of Trusts in 1935
2 Sections 2 and 3 of the Charities Act 2003

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that were fist witnessed in Britain’s Virgin Islands. The circumstances listed under non-
charitable purpose trusts are renovation of gravesites, monuments and tombs, financing religious
activities and services, financing “off-balance sheet”, taking care of animals, and some financing
business expeditions.
Non-charitable purpose trusts are authorized by the “Uniform Trust Code” if they are not meant
to be “wasteful” or “capricious”. Non-charitable trusts emerged in England in the 19th Century.
Charitable trusts, on the other hand, were already enforceable in England by the 15th century
courtesy of the Chancery.3 Non-charitable purpose trusts were at loggerheads not only with the
beneficiary principle, but also the “Rule of Perpetuities” and the “Certainty Principle”. The
contravention occurred before the introduction of the “Uniform Trust Code”. However, the
courts had already began circumventing the particular laws that prohibited “non-charitable
purpose trusts”. The courts went as far as developing an exception (honorary trusts) to the
beneficiary principle so as to create a statutory solution for non-charitable purpose trusts’ cases.
Honorary trust was developed in the 20th century; the trust did not compel trustees to include the
purpose of the trust, but rather it bound them through honor.
Analysis
Agree Critics
There are certain cases where non-charitable purpose trusts have to be upheld by virtue of the
“purpose” being relevant. For instance:
Graves, Monuments, and Tombstones
England courts in the past treated trusts for these three circumstances as private trust which were
to be ruled in compliance with the “Rule of Perpetuities”. In the case of Meehan v Hurley [1930],
the deceased had requested that flowers worth $500 be bought and placed on her grave yearly
during Christmas, Decoration Day, and Easter4. That was a relevant purpose which the trustees
declared that would last for 7 years. However, the court held that the trust corpus could extend
beyond the time required by the “Rule of Perpetuities”; therefore, it was void. It was not logical
or possible for the trustee to enforce the bequest for an indefinite time that is why it was ruled as
invalid.
3 Ausness, Richard C. "Non-Chritable Purpose Trusts: Past, Present, and Future." (2016).
4 Meehan v Hurley [1930] 51 R.I. 51, 150 A. 819

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Religious services and mass requiems for the dead
Performing masses for the dead (Roman Catholic Rituals) was declared illegal by statute during
the “Protestant Reformation” in medieval England. The rituals were validated in 1919 by the
House of Lords in the case of Bourne v Keane5. The House of Lords initially held that the
performance of masses for the dead was void not because they lacked beneficiaries, but because
it was a superstitious activity. The court later on validated the said mass and came up with the
“Bourne [1919] Principle” which required masses to be conducted in private. Public masses are
considered as charitable events.
Trusts for taking care of animals
When gifts are issued with the intent to maintain animals that becomes a charitable object. Trusts
for maintaining animals (pets) are, on the other hand, private purpose trusts that are considered to
be valid. In the case of Pettingall v Pettingall [1842], the testator has entrusted funds to the
executor to maintain the testator’s black mare; the executor was to spend £50 yearly6. The
executor was required to keep the surplus upon the testator’s death. The executor’s legitimate
willingness to execute the testator’s wish created a trust for the benefit of the mare. The
residuary legatees were to act as oversight to ensure that the trust was executed; they were not
regarded as beneficiaries of the trust. However, they were revealed to have intended to ensure the
trust’s failure not the validity of the trust.
The English courts further expanded the scope of the “Pettingall Principle” in the case of Re
Thompson [1934]. The testator had trusted some funds to the executor to promote and further the
hunting of foxes7. The court held that the trust for fox hunting was valid. However, in cases
where the trust infringed on the perpetuity rule, the trust is invalidated. There has to be a clear
definition of who will execute the trust.
The author in this case intended to explain the circumstances under which non-charitable
purpose trusts can be validated. However, citing the “Rule of Perpetuities” several times tends to
stray from the article’s main idea. The listed circumstances are relevant that is why this paper
agrees to the English law’s idea of upholding the circumstances.
5 Bourne v Keane [1919] A. C. 815
6 Pettingall v Pettingall [1842] 11 LJ Ch 176
7 Re Thompson [1934] ch 342

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Disagree Critics
The author states that the various doctrines that invalidate the non-charitable purpose trusts. A
close review of the doctrines makes this paper disagree with the author’s intention in that
particular section.
The Beneficiary Principle
Trusts impose certain enforceable obligations on trustees. Beneficiaries are the people with the
capacity of enforcing such obligations.8 Such persons are granted general rights in relation to the
enforcement of the trusts’ subject matter. This principle was advanced by Justice Roxburgh in
the case of Re Astor Settlement Trusts v Astor V Scholfield [1952]. Waldorf Astor requested that
the money earned from his shares in “The Observer” were to be used in the preservation of peace
between nations. The trust was challenged with the challengers citing that the trust was for
abstract purposes and it did not benefit real people9. The judge held that the trust was invalid on
the basis that it was uncontrollable and unenforceable.
Peace is an important factor in the society. This principle impedes the progression of vital virtues
in the society, in particular peace.
The Uncertainty Principle
The trust in the Re Astor [1952] also failed because it was not certain to who the rights belong;
who was to enforce the trust? The judge stated that, “If an enumeration of purposes outside the
realm of charities can take the place of an enumeration of beneficiaries, the purposes must be
stated in phrases which embody definite concepts and the means by which the trustees are to try
to attain them must also be prescribed with a sufficient degree of certainty.” The objects of the
trust are also expected to be certain according to Judge’s Roxburgh’s ruling.
Non-charitable purpose trusts are intended for particular purposes and the certainty of who owns
the rights of the trust need not be an issue. In the case of Re Astor, the trust was meant to
maintain peace (there is a defined purpose). That is particularly why this paper disagrees with the
uncertainty principle.
8 Ramjohn, M, Unlocking Equity and Trusts (6th edn, Routledge, 2017)
9 Re Astor Settlement Trusts v Astor V Scholfield [1952] [1952] Ch 534, [1952] 1 All ER 1067, [1952] 1
TLR 1003

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The Perpetuity Rule
The rule of perpetuities defines the period within which the vesting of real or personal property
may be postponed (the remote vesting rule). It is statute of general application found under
common law. It also declares the period within which vested property in the rule of beneficiaries
can be retained (the excessive duration rule). The “Perpetuities and Accumulations Act 2009”
did away with the period stated under common law and created a standard of 125 years for
general purposes and 21 years where life was involved (trusts for private purposes)10. The period
is measured from the time the testator dies and the executor commences the execution of the
trust.
This paper disagrees with the principle based on the fact that life in the case of some animals can
last very long. For instance, elephants and tortoises are known their life longevity.
Conclusion
There are circumstances under which the English law has to uphold the purpose trusts. The trusts
are created as a result of the testation of assets to trustees for specific objectives. The certainties
required are:
 the settlor’s intention to establish a purpose trust
 the existence of the property to be entrusted
 the objectives (purposes) for which the settlor established the trust must be clarified; this
helps in circumstance where the trust is challenged in court and certainty has to be
established.11
The intended objectives of the purpose trusts have to be consistent with the perpetuity rule,
certainty rule, and the beneficiary principle. The consistency ensures that there are no future
inconveniences when the trusts are challenged. The perpetuity rule declares a period of 125 years
for the existence of purpose trusts.12 However, where life is concerned, the period is 21 years.
The trusts must include the trustees. The trustees are expected to execute the trusts in compliance
10 Perpetuities and Accumulations Act 2009
11 Riches J, Equity and Trust (2nd edn, Routledge 2017)
12 'Bits Of Law | Trusts | Formation | Purpose Trusts: Overview' (Bitsoflaw.org, 2019)
<http://www.bitsoflaw.org/trusts/formation/revision-note/degree/creation-purpose-trusts-charity> accessed 17 May
2019.

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with the law of trusts.13 In as much as the English law upholds the trusts at the expense of the
beneficiary principle, the laws should be complied to; this helps in avoiding invalidation of the
trusts. The law of trusts requires trustees to be compensated and paid for their services and
expenses incurred because of trust property.
It is necessary for purpose trusts to have enforcers who have “to enforce the trust in relation to its
non-charitable purposes”. The enforcer ensures that the trustee has utilized the trust funds for the
purposes they are meant for; it prevents misuse of trust property. This ensures that the activities
of trustees are monitored and any circumstance of misconduct challenged in a court of law. The
Law of Trust does not expect trustees to benefit from the trusts in terms of profit either directly
or indirectly. The enforcer and trustee have to be separate individuals. The roles of enforcers and
trustees must be clearly defined and drafted in order to prevent the collision of duties.
Purpose trusts are used:
 “to hold the shares in special purpose vehicles (spvs) used in connection with
securitizations or off-balance sheet transactions where there is often a preference for the
spv to be “orphaned” from the parties to the transaction”14
 “to hold the shares of a private trust company which acts as trustee of a settlor’s family
trust. Such an arrangement provides a greater degree of comfort for the settlor about the
composition of the board of directors of that private trustee than would otherwise be the
case if an unconnected trust company acts as trustee of such family trust. Such a private
trust company can also be useful for family offices, as it can act as trustee of a number of
linked family trusts”15
 “to hold shares in a family business to aid with succession, with the trustees acting
neutrally and independently of family dynamics”16
 “for investing in family companies where economic performance is likely to be poor or
uncertain”17
13 Watt, G, Equity & Trusts Law (5th edn, Oxford University Press, 2016)
14 Penner, J. E, The Law of Trusts (10th edn, Oxford University Press, 2016)
15 (Ibid, n 18)
16 (Ibid n 19)
17 (Ibid n 19)

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 “for social benefit projects (both public and private) to enable certain community
facilities or areas to be maintained, for the preservation of monuments, to provide
financial support and to fund particular political purposes”18
Purpose trusts evolve over the years; therefore, trustees should anticipate changes and variations
when the purpose trusts are challenged.19
Question 2
Introduction
A will trust (testamentary trust) is created to protect the family’s property that you intend to pass
on to your lineage. When the testator dies, he or leaves a will behind defining how the property
or money should be distributed. However, there are many situations that may prompt the
modification of the will. A person may decide that there are vital issues that may require a
modification of the will. The beneficiaries should; therefore, liaise with the trustees to find the
right course of action in case a variation on the will is needed.
Duties of trustees
Section 1 of the “Trustee Act 2000” defines the general duty of care owed to beneficiaries by
trustees. The trustee
“must exercise such care and skill as is reasonable in the circumstances, having regard in
particular -
(a) to any special knowledge or experience that he has or holds himself out as having, and
(b) if he acts as trustee in the course of a business or profession, to any special knowledge or
experience that it is reasonable to expect of a person acting in the course of that kind of business
or profession.”20
The duty provided creates an objective care for trustees to exercise "such care and skill as is
reasonable in the circumstances". However, a professional trustee is held of higher standard
18 (Ibid n 19)
19 'Private Purpose Trusts |' (Lawexplores.com, 2019) <https://lawexplores.com/private-purpose-trusts/>
accessed 17 May 2019.
20 Trustee Act 2000

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compared to a family trustee. The special skills portrayed by such trustees like accountability
enables the trustee to have a higher degree of care over the beneficiaries. If the duty of care is not
excluded by the instruments of trust, then it must be implemented “when:
 acquiring or managing land;
 appointing or reviewing agents;
 dealing with audits and valuations of trust property;
 exercising powers to compound liabilities;
 insuring trust properties;
 investing trust capital.”
In the case of Speight v Gaunt [1883], Lord Blackburn held that "as a general rule a trustee
sufficiently discharges his duty if he takes in managing trust affairs all those precautions which
an ordinary prudent man of business would take in managing similar affairs of his own"21; this is
termed as objective care. Lay trustees cannot be held to the standards and qualifications of a
professional trustee. Similarly, a professional trustee cannot be belittled to the standard of a lay
trustee.
Investment powers
Section 3 (1) of the “Trustee Act 2000” states that "subject to the provisions of this part, a trustee
may make any kind of investment that he could make if he was absolutely entitled to the assets
of the trust"22. The act makes it possible to stand in as investors on behalf of the beneficiaries. If
there is an investment opportunity, the trustee is expected to seize it accordingly and ensure
maximum effort and success. The 2000 Act is considered as objective compared to the Trust
Investments Act 1961 which was known for the "very conservative investment policy for
trustees"23. The act gave trustees very limited powers in as far as investment is concerned. The
2000 Act, on the other hand, gives trustees the power to make investments unless the trust
instruments prohibited investment of the money. The policy applies retrospectively to trusts
established before the act was enacted. The exceptions are trusts under the “Authorized Unit
21 Speight v Gaunt [1883] UKHL 1
22 Trustee Act 2000
23 Trust Investments Act 1961

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Trusts, Charities Act 199324, and Occupational Pension Scheme”. Section 4 of the 2000 Act
direct trustees to look at the “standard investment criteria” when making investments. The
investment has to be suitable to the trust and must be in the best interest of the beneficiaries. In
the case of Cowan v Scargill [1985], Megarry VC recommended that the trustees be granted an
overriding duty to make investments at the beneficiaries’ best interests, unless the instruments of
the trust state otherwise25. Scargill wanted to make investments on with the mineworkers’
pensions but was stopped by the court since it would bring less money; this would be considered
as breach of trust.
Application
The “Trustee Act 2000” expects trustees to exercise the mandatory and objective duty of care
owed to beneficiaries. They should exercise powers on the trusts in the best interests of the
beneficiaries as if they were acting upon their own interests. Guy’s request was that the trustees
pay 17,000 sterling pounds as Colin’s fees at the Midshire Music Academy which is renowned
internationally. The teachers had discovered Colin’s music prodigy and, therefore, advised Guy
on the best course of action. Paying the fees using the trust funds is considered to be an act to the
best interest of the beneficiary (Colin). The trustees know that the move would improve Colin’s
stature as well as his music prodigy. Guy’s request should be granted.
Beth intends to join the University of London and needs a yearly fee of 10,000 sterling pounds.
A reasonable trustee would not need much explanation in order to finance the Beth’s university
education. Even though the trust does not specify if it can be used for educational purposes, the
trustee has the power to act on it since it is at the best interest of the beneficiary (Beth). The
request should be doubtlessly granted.
Anna, on the other hand, seeks 50,000 sterling pounds to help finance Tim’s bid to establish a
long medical practice. That would also include a Georgian house that Anna and Tim (Anna’s
husband) will live in. The “Trustee Act 2000” expects trustees to act upon investments that are in
the best interests of the beneficiaries. Investing the trust in Tim’s long medical practice would
guarantee Anna a comfortable life. Is the investment suitable to the trust? Since it assures Anna
24 Charities Act 1993
25 Cowan v Scargill [1985] ch 270

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of a reliable source of income, it is considered as suitable. I would advise the trustees to grant
Anna the request.
Conclusion
Will trusts are very difficult to execute especially in circumstances where the beneficiary
requests a change in it. Trustees are expected to grant beneficiaries their wishes if the deed falls
within an objective duty of care or a suitable investment. Paying for education, talent promotion,
and business investment is a suitable and objective duty of care for trustees to beneficiaries.
Question 3
Discretionary trust wills
Discretionary trust wills involve leaving the estate or property to a trust to manage it on behalf of
the beneficiary. Discretionary trust is useful in circumstances where the testator does not have
the time to make a will; the power of deciding on the sharing of the property is passed on to the
trustees. The trust is meant to protect the assets until the beneficiary is capable of managing the
property. In this case study, one of the trustees died and the other is expected to retire. What are
the circumstances under which a trustee can retire? This section of the paper will look at what
the law provides for the retiring of trustees.
Legislation on trustees retiring
The “Trustee Act 1925” gives statutory powers for trustees to be able to voluntarily retire. The
retirement should come about “since:
 all the beneficiaries (being of full age and capacity) require it,
 by the exercise of an express power contained in the trust deed; or
 by order of the Court.”26
Section 39 (1) of the “Trustee Act 1925” provides:
“Where a trustee is desirous of being discharged from the trust, and after his discharge there will
be either a trust corporation or at least two persons to act as trustees to perform the trust, then, if
such trustee as aforesaid by deed declares that he is desirous of being discharged from the trust,
and if his co-trustees and such other person, if, any, as is empowered to appoint trustees, by deed
26 Trustee Act 1925

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consent to the discharge of the trustee, and to the vesting in the co-trustees alone of the trust
property, the trustee desirous of being discharged shall be deemed to have retired from the trust,
and shall, by the deed, be discharged therefrom under this Act, without any new trustee being
appointed in his place.”
Section 39 states that a trustee can only retire voluntarily if there will be at least two other
trustees left to be in charge of the property or estate. That should be done by deed that needs to
be signed by the relevant people; in this case it could be the other two trustees, the retiring
trustee, and a person given the power or capacity to appoint trustees. Initially when a trustee
retired, the trust would be managed by Trust Corporation.
A beneficiary can help the trustee retire by bringing the trust to an end (that is, when they attain
the full age and capacity). Otherwise, the beneficiary cannot, on normal circumstances,
orchestrate the retirement of a trustee whether or not there will be a replacement.27 The rule of
bring an end to the trust in order to retire a trustee was established in the case of Saunders v
Vautier [1841]. The case not only creates the rule of beneficiaries requiring trustees to retire by
bringing the trust to an end upon attaining full age, but also has other expansive applications28.
“At its most expansive the rule in Saunders v. Vautier can be thought of as the rule which allows
a beneficiary(s) to ignore the testator’s/settlor’s intentions and vary the terms of a trust. It stands
for the proposition that if all potential beneficiaries of a trust, collectively representing 100% of
the potential “ownership” of the assets of the trust, unanimously direct that the trust is to be
wound up and/or varied, the trustee(s) must act in accordance with the beneficiaries’ direction
regardless of whether such direction goes against the testator’s/settlor’s “intention” in
establishing the trust.”29
The rule derived from Saunders v Vautier under common law is that beneficiaries could depart
from the original trust plan set by the testator upon attaining full age or legal capacity. The
beneficiaries have to be entitled to the full beneficial ownership of the trust property. However, if
27 Gill Steel, 'Retirement Of Trustees' (Lawskills, 2019)
<https://www.lawskills.co.uk/articles/2010/03/retirement-of-trustees/> accessed 17 May 2019.
28 Saunders v Vautier [1841] EWHC J82, (1841) 4 Beav 115
29 'Saunders V. Vautier – What Does It Mean? - Hull & Hull LLP' (Hull & Hull LLP, 2019)
<https://hullandhull.com/2018/01/saunders-v-vautier-mean/> accessed 17 May 2019.

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any of the beneficiaries (no matter how remote the variation is) refuses to get along with a
change in the settlement of the trust property, then the initial trust settlement is upheld; in that
case the rule in Saunders v Vautier is not utilized.
Application
Using the provisions of the “Trustee Act 1925”, Brian can only retire if the beneficiaries attain
full and legal capacity and they require him to retire. The decision has to be backed up by an
express power provided by the trust deed or a court order. According to Section 19, Brian will
only be allowed to voluntarily retire if there will be two other trustees left to take charge of the
trust property. In this case, only Jack Healey will remain since Colin passed on. The only
relevant option Brian has is to apply for an administration order. Through that order, the court
can discharge Brian and get him an early retirement without appoint his replacement. If it is
established that Jack has the capacity to manage the trust property, then the court will be obliged
to grant Brian the retirement. The Saunders v Vautier rule can only applicable if the
beneficiaries, after reaching the full age, bring the trust to an end, thus retiring Brian. The
beneficiaries would also be able to retire Brian on a general vote accepted by all of them
(provided the legal capacity and full age are attained.

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Bibliography
Journal Articles, Books, and Reports
Ausness, Richard C. "Non-Charitable Purpose Trusts: Past, Present, and Future." (2016).
'Bits Of Law | Trusts | Formation | Purpose Trusts: Overview' (Bitsoflaw.org, 2019)
<http://www.bitsoflaw.org/trusts/formation/revision-note/degree/creation-purpose-trusts-
charity> accessed 17 May 2019
Penner, James, The Law of Trusts (10th edn, Oxford University Press, 2016)
'Private Purpose Trusts |' (Lawexplores.com, 2019) <https://lawexplores.com/private-purpose-
trusts/> accessed 17 May 2019
Ramjohn, M, Unlocking Equity and Trusts (6th edn, Routledge, 2017)
Riches J, Equity and Trust (2nd edn, Routledge 2017)
'Saunders V. Vautier – What Does It Mean? - Hull & Hull LLP' (Hull & Hull LLP, 2019)
<https://hullandhull.com/2018/01/saunders-v-vautier-mean/> accessed 17 May 2019
Steel G, 'Retirement Of Trustees' (Lawskills, 2019)
<https://www.lawskills.co.uk/articles/2010/03/retirement-of-trustees/> accessed 17 May 2019
Watt, G, Equity & Trusts Law (5th edn, Oxford University Press, 2016)