#equity #law #secret-trust
In Re Keen (above), the court referred to obiter statements in the speeches in Blackwell v Blackwell and went on to hold that, in half-secret trusts, communication cannot take place after the will. Lord Wright MR said that this ‘would involve a power to change a testamentary disposition by an unexecuted codicil and would violate s 9 of the Wills Act’.
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