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#equity #law #secret-trust
In Re Young [1951] Ch 344, a secret trust benefited the testator’s chauffeur, who had witnessed the will. The Wills Act, s 15 provides that a witness to a will cannot benefit under that will. The court held that the chauffeur was entitled under an oral trust declared inter vivos. Danckwerts J said:

a beneficiary under a secret trust does not take under the will, and … he is not, therefore, affected by s15 of the Wills Act 1837.

He was, therefore, entitled to benefit.
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