In Re Tilley’s WT [1967] Ch 1179, however, the claimant (strictly speaking her personal representative) was not allowed a proportionate share of a house bought by the deceased female trustee, apparently inadvertently using some trust money in her account, before she died leaving enough in her residuary estate to cover the amount of the claim. Ungoed-Thomas J was kind to the elderly woman, seemingly regarding her as an ‘innocent’ trustee so that since she could have bought the house without recourse to the trust money, no proportionate share was permitted (though the judge admitted that he would have imposed a lien over the house to secure the money claim if requested). This approach seems fair for innocent volunteers who would have used their own money if they had realised that some of the money being used was trust money, but Mrs Tilley was trustee of her husband’s estate for herself for life remainder for her claimant daughter- and Mrs Tilley was a successful businesswoman