#equity #formalities #law
Unfortunately, without full consideration of the issue, Lawrence Collins LJ, obiter dicta in Nelson v Greening and Sykes (Builders) Ltd [2007] EWCA Civ 1358 at [56-58] opined that declarations of sub-trusts fell outside s 53(1)(c ), while in Kaye v Zeutal [2010] EWCA Civ 159 at [37] the court assumed that this was the case.
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