Palmer v Simmonds (1854) 2 Drew 221 The testatrix gave her residuary estate to Thomas Harrison ‘for his own use and benefit, as I have full confidence in him, that if I die without lawful issue he will . . . leave the bulk of my said residuary estate’ to specified persons. The use of the words ‘full confidence’ at that time would have been sufficient to create a trust. The court held the phrase ‘the bulk of my estate’ was not sufficiently certain for a trust, so Thomas Harrison took the property absolutely. A trust of an unidentified section of chattels (tangible property) will fail, whereas a trust of an unidentified section of intangible property, such as shares, is valid.