1. Examples
   1. Re Shaw, Public Trustee v Day [1957] 1 WLR 729
      1. to develop a 40 letter alphabet
   2. Re Endacott (Deceased) [1960] Ch 232
      1. 'providing some useful memorial to myself'
   3. Re Astor's Settlement Trusts [1952] Ch 534
      1. 'maintenance of good understanding between nations and the preservation of the independence and integrity of newspapers'
2. Beneficiary Principle
   1. Exceptions
      1. Particular animals
         1. Re Dean (1889) 41 ChD 552
      2. Maintenance of graves or monuments
         1. Pirbright v Salway [1896] WN 86
      3. Described as anomolous in Re Astor and Re Endacott
   2. Trusts framed as trusts for people
      1. Re Denley's Trust Deed [1969] 1 Ch 373
         1. Land was to be used as a sports ground, primarily for benefit of employees
         2. Benefit to individuals is sufficiently tangible to give them standing to enforce the trust
         3. Unclear whether a factual benefit will suffice, or an equitable interest is necessary
      2. Must also satisfy...
         1. Rule against inalienability
            1. 21 years
         2. Certainty of objects
            1. Purpose
            2. Must be sufficiently certain
            3. Beneficiaries
            4. Likely to be given postulant test
            5. Must be reasonable number
            6. R v District Auditor, ex parte West Yorks Met. County Council [1985] 26 RVR 24
3. Certainty of Objects
   1. The purpose must be sufficiently certain to enable the trustees to apply the funds
      1. Eg Re Astor
4. Rule Against Inalienability
   1. Duration limited to 21 years
   2. Or for 'as long as the law allows'
   3. Must make it clear that capital can be spent on purpose
   4. OR make the trust charitable
5. Useless or Capricious Purposes
   1. Brown v Burdett (1882) 21 ChD 667
6. Quistclose Trusts
   1. Interpreted in Twinsectra
   2. Was the primary trust a purpose trust?
   3. Lender passes legal title to borrower, but retains beneficial interest under a resulting trust
   4. The lender is therefore the beneficiary of the resulting trust