Also see Shah v Shah [2010] EWCA Civ 1408. In that case, the Court of Appeal construed a letter referring to a transfer of shares as a declaration of trust of the shares, rather than a gift. The transferor delivered a letter to the transferee, M. The letter referred to the transferor ‘holding’ shares for M and describing the letter as a ‘declaration’. The transferor did not, however, deliver the share certificates to M, and the forms of transfer and then registration were not completed until a later date. The transferor later challenged the disposition on the ground that the letter constituted a gift, and, as the gift was not completely constituted, it was of no effect. The CA held that on construction the letter was a declaration of trust. This trust took effect until the transfer of legal title took effect by registration of the donee.