Where a donor intends to make a gift during their lifetime but fails to vest the legal estate in the donee, the gift may still be perfected if legal title vests in the donee because they become personal representative to the donor (now deceased), provided the donor had a continuing intention to make the gift up until death. In Strong v Bird (1874) LR 18 Eq 315, Bird borrowed £1,100 from his stepmother who was living with him, paying £212 rent per quarter. The loan was to be repaid, over 11 quarters, by the stepmother deducting £100 per quarter from the rent paid to Bird. She made the deductions for two quarters but then expressly forgave the debt and insisted on paying the full rent per quarter till her death. Bird was appointed her executor and proved her will. The stepmother’s residuary legatees sought an account of Bird for the £900 balance on the basis that the oral release of the debt was ineffective. Jessel MR held that the debt was released at common law by Bird’s appointment as executor as he could not sue himself. Although in equity Bird would normally have been liable to account, this was displaced by proof of the stepmother’s unchanged intention to forgive the debt followed by Bird becoming her executor, so that by her act of making him executor he was not able to sue himself at common law In Strong v Bird equity passively allowed the simplistic common law position to prevail, so that what would normally have been the imperfect release of a debt was perfected.