In Grey v IRC Mr Hunter had intended that the value in the shares should pass from himself to the beneficiaries of the six separate settlements by virtue of the oral direction to the trustees to hold the shares on the trusts of the settlement (step 3). It was argued that the term ‘disposition’ was limited in its meaning to ‘grants and assignments’, so that the oral direction was not a ‘disposition’ within s 53(1)(c) and hence did not need to be in writing. The House of Lords took the view that the oral direction was an attempted disposition of subsisting equitable interests and was ineffective since it was not in writing as required by LPA 1925, s 53(1)(c). Accordingly, the disposition of the subsisting equitable interests had been made by virtue of the confirmatory deed executed by Mr Hunter. That being a document which passes value, ad valorem stamp duty was leviable thereon. In the House of Lords, Lord Radcliffe said that the word ‘disposition’ in s 53(1)(c) covered all means and devices whereby an equitable owner effectively transfers an interest to someone else. Although it seems reasonably clear that the oral direction was a ‘disposition’ within the meaning of s 53(1)(c), it is less clear why the House of Lords levied duty on the deed. If the parties intended the deed merely to confirm a state of affairs, it does not follow that, if that state of affairs had failed to come about, the deed – intended to be confirmatory – should bring about that state of affairs. The deed, however, may well have been intended as a fallback to oust surtax payable by Mr Hunter if the shares had throughout remained beneficially owned by him.