Re Golay’s Will Trusts [1965] 2 All ER 660 The testator directed his executors to allow the beneficiary to ‘enjoy one of my flats during her lifetime and to receive a reasonable income from my other properties.’ It was held that the trustees could select a flat (it is arguable that there was uncertainty as to which flat it should be, but this was not raised as an issue in the case) but the question arose as to whether the direction for ‘a reasonable income’ was void for uncertainty. Ungoed-Thomas J held the gift valid.