Blackwell v Blackwell [1929] AC 318 suggests that secret trusts operate outside (dehors) the will and are therefore not subject to the Wills Act. It would appear that communication and acceptance create the trust inter vivos. The will does not create the trust, it is merely the device for constituting it by transferring the property to the trustees. The trust is thus ‘dehors’ or outside the will. If this is correct, it would seem to apply to both fully and half-secret trusts, which makes it illogical in the case of half-secret trusts not to allow communication after the date of the will but before the testator’s death, claiming that otherwise the Wills Act would be avoided.