Re Gulbenkian's Settlements (1970)
[1970]
AC 508 HL.
This was a case concerned power of
appointment with a gift over in default. A settlement provided a power of
appointment to be applied to anyone who was providing accomodation or care for
Mr Gulbenkian or his family with a gift over
in default of appointment.The issue was whether the settlement provided sufficient certainty
of objects for it to be carried it?
Held: ( HL – Lord UpJohn)
Although it was not possible to
ascertain every possible objects ( beneficiaries) of the appointment, it was
possible to determine whether a particular person was a potential appointee or
not. Thus, It was held that the settlement had provided sufficient certainty of
object. This case laid down the test for certainty of objects for power – the “ Is or Is Not test” or “Any given postulant” test.