In Re Ralli’s Will Trusts [1964] Ch 288, a testator left property on trust for his wife for life, remainder to his two daughters equally. His daughter, Helen, covenanted in her marriage settlement to settle property including after-acquired property on certain trusts. She died, a childless widow, while her interest under her father’s will was still in remainder. On her mother’s death, Helen’s interest fell into possession. X was then the sole surviving trustee of the father’s will trusts and, as such, the legal title to the property subject to the will trusts was vested in him. X was also the sole surviving trustee of Helen’s marriage settlement, and he asked the court whether Helen’s interest under her father’s will trusts formed part of her estate or should be held on the trusts of Helen’s settlement, for beneficiaries who were volunteers as next of kin of Helen, not being children within the marriage consideration for the settlement. It was held that X held the property on the trusts of Helen’s settlement. First, because Buckley J construed a clause in the settlement as declaring a trust of Helen’s subsisting interest in remainder pending an assignment to the trustees (which never took place). Second, when X acquired the title to the property, the settlement became completely constituted. As Buckley J said, He is at law the owner of the fund and the means by which he became so have no effect on the quality of his legal ownership. This outcome was only possible because X happened to be trustee of both trusts. This case has been criticised by some writers, who view it as an unjustifiable extension of the rule in Strong v Bird. Although the judge appeared to see it as a development from that rule, he made no reference to the requirements regarding intention which normally apply. Furthermore, the judge was not referred to Re Brooks’ ST [1939] 1 Ch 993 where there was a marriage settlement for W for life, remainder to her children equally, with W having a power to appoint capital by deed or will to such of her children as she thought fit. In 1929 one adult child, A, made a voluntary settlement in which he purported to assign to Lloyds Bank as trustee not just his subsisting interest in remainder but anything that might subsequently be appointed to him. In 1939 his mother appointed £3,517 to him, by which time Lloyds Bank had also become trustee of her marriage settlement. A demanded that the bank pay him the £3,517 but the bank took out a summons to determine whether it had to pay him the money or whether it should be held on the terms of his voluntary settlement. Farwell J held that it was impossible for A to make a gift of future property to anyone and that it followed that he was entitled to the £3,517, fortuitously held by the bank in circumstances where neither A nor his agent had been responsible for the bank having the money and neither had authorised the bank to hold that money on the trusts of A’s voluntary settlement.