Traditionally, after transferring specific property to trustees, a covenant would be inserted in the trust deed to the effect that any property subsequently inherited from any relative would also be transferred to the trustees, so as to keep the ‘family nest egg’ intact. There would then be a completely constituted trust of the transferred property but not a completely constituted trust of the non-existent, future after-acquired property mentioned in the covenant. The covenant itself is, however, an existing chose in action even though not crystallising into an enforceable right till occurrence of the event specified in the covenant: Re Landau [1997] 3 All ER 322 at 328.