In Re Freeland, [1952] Ch 110, the Court of Appeal made it plain that there must have been an intention to make an immediate gift. The plaintiff and the defendant were the executrices of the testatrix. The plaintiff laid claim to a Hillman motor car. The plaintiff claimed that the testatrix ‘gave’ (in the popular sense) her the car. However, it was an imperfect gift because there was no delivery. The plaintiff claimed the imperfection was cured by the rule in Strong v Bird on her appointment as executrix. Evershed MR rejected the plaintiff’s claim and pointed out that the headnote to Re Stewart was liable to mislead: an intention of giving (present tense) rather than an intention to give (future) is required, whereas in Re Freeland, the testatrix had only intended to give the plaintiff the car in the future after it had been put in running order and lent to a third party. So there was no intention to make an immediate gift. It also follows that, for the rule to apply, the gift must relate to existing property, not future (or after acquired) property.