The Commission is also authorised to appoint new trustees to replace removed ones, or even to increase the number of trustees. The definition has developed from the 1601 charitable uses act and the ruling in IRC v Pemsel (1891) Re Coulthurst (1951) IRC v Baddeley (1955) Dingle v Turner (1972) The ruling of Re Coulthurst stated that the poverty being experienced did not need to be complete destitution and Lord Evershed stated poverty is a relative term not absolute term. Lord Herschell: I certainly cannot think that they . He claimed to be entitled to a judicial pension. The other problem is that it may be seen as a class within a class as in case of IRC v Baddeley (1955). Oppenheim v Tobacco Securities Trust Co Ltd [1951] AC 297. IRC v Oldham Training & Enterprise Council [1996] STC 1218. trust to set up unemployed in trade or business & enable them to stand on their own feet held to be charitable for the relief of poverty ; . [45], This definition and the acceptance of the need for a "public benefit" allows the courts to reject charitable trusts for recreational activities, such as if they felt that the activities are harmful. [8], The first definition of a "charitable purpose" was found in the preamble to the Charitable Uses Act 1601. Because of this lack of a relationship, the trustees' powers are far wider-ranging, only being regulated by the Charity Commission and actions brought by the Attorney General; the beneficiaries have no direct control. Re Compton. LORD HALSBURY L.C. Scottish Burial Reform and Cremation Society v Glasgow City Corporation, 38 'the law of charity is a moving subject which evolves over time'. He had been detained in Barlinnie priosn. The defendants (H) were the owners of a hotel. Other cases such as Goodman v Saltash (1882) and Peggs v Lamb 1993 have held that trusts for people in a definite geographical area are charitable. The courts have added to the list of purposes which are accepted as charitable and in 1891 Lord McNaughton (Pemsel Case 1891 Ac 531) classified four heads for charitable purposes. v. Pemsel.1 Pemsel's Caseis considered to be the major judicial approval of the classification of charitable purposes and charitable objects. Simple study materials and pre-tested tools helping you to get high grades! A charity does not have to be for the benefit of people who are both poor, impotent and aged to be valid, only one of them. We and our partners share information on your use of this website to help improve your experience. This legal concept has been applied and adapted over the centuries by the judiciary in both the United Kingdom and Australia. An illustration of its strictness is Bowman v Secular Society, where it was held that even when attempted changes to the law were ancillary to the main goals, it was still unacceptable. However in, the first gift the courts may feel that the unemployed may not be a large section of the public as this depends on the economy of the country. His role was discussed in Brooks v Richardson,[61] where the court quoted the practitioner's text Tudor on Charity: By reason of his duty as the Sovereign's representative protecting all the persons interested in the charity funds, the Attorney-General is as a general rule a necessary party to charity proceeding. A-G [1972]: law reports = educational t/f yes London Hospital Medical College v IRC [1976] ; AG v Ross [1986]: Student unions/organisations ancillary to education t/f yes. The issue between the approaches falls down to whether Lord Crosss approach which requires a intrinsically charitable in the creation of a trust or as with the Compton approach which requires just a evidential issue of showing that there is a predominantly public benefit rather than a private benefit, is correct. Any opinions, findings, conclusions, or recommendations expressed in this material are those of the authors and do not reflect the views of LawTeacher.net. Similarly, in . p 366, and, in a more modem context, Lawrence W in Keren Kayemeth Le Jisroel Ltd v IRC (1931 . An organisation whose aims could be seen as harmful to the public could not be recognised as a charity. This results in two things; firstly, the trustees of a charitable trust are far freer to act than other trustees and secondly, beneficiaries cannot bring a court case against the trustees. The House defined what is meant at law by a charity. If you are the original writer of this essay and no longer wish to have your work published on LawTeacher.net then please: Our academic writing and marking services can help you! The question refers to the fourth category of charitable trusts called trusts for other analogous purposes within the spirit and intendment of the Preamble to the Statute of Charitable Uses 1601 which was distilled by Lord Mcnaghten in the case of Commissioners of Income Tax v Pemsel. [60], The next significant role is played by the charity trustees, defined in Section 97 of the 1993 Act as those persons having the general control and management of the administration of charities. The guiding principles in such cases are as follows: where connecting word is or this is construed disjunctively which means the trust is not to be regarded as exclusively charitable e.g. Info: 2112 words (8 pages) Essay Rather, the beneficiaries are represented by the Attorney General for England and Wales as a parens patriae, who appears on the part of The Crown. It provides for situations where political activity can be carried out, in order to support the delivery of its charitable purposes. viz., that they were for the relief of poverty. What were the four heads of charity under pemsel and which judge said them. The most important feature here is that the Charities Act 2006 removes the presumption, it provides s3(2), the public benefit requirement must be demonstrated in all cases, not just in the first three heads of Lord Macnaghtens classification. I do not question that there may be a good charity for the relief of persons who are not in grinding need or utter destitution: see In re de Carteret [1933] Ch. [50] There is a dividing line; charitable trusts discussing political issues can be valid, as discussed by Hoffmann J obiter dicta in Attorney General v Ross. Hence again in Morice v Bishop of Durham (1805) and Re Gillingham BUD DF (1958) have held that the effect of using such words is that the trust is not be exclusively charitable. [16], The "poverty" category is a "major exception" to the rule on personal relationships laid down in Oppenheim v Tobacco Securities Trust. (v) Defined contribution plans subject to the funding standards. [74], Failures that lead to an application for cy-pres are of two sorts; subsequent failure, where the trust, constituted properly, failed after a period of action, and initial failure, where the trust fails at creation. Individuals who donate via Gift Aid are free from paying tax on that amount, while companies who give gifts to charity can claim tax on the amount back from HM Revenue & Customs.[6]. It has been argued that there has been a weakening in the courts attitude to purportedly charitable trusts recently. Updated: 17 November 2021; Ref: scu.220239. Jurisdiction over charitable disputes is shared equally between the High Court of Justice and the Charity Commission. 2 Nowadays they are regulated by the principles in the Charities Act 2011 which repealed the Charities Act 2006. [51] This line is considered by the Charity Commission in their official guidelines, which allow the Commission to look at the wider purpose of the organisation when deciding if it constitutes a valid charity. IRC v McMullen [1981] AC 1 at 15 (Lord Hailsham). The purposes (sometimes referred to as "objects") of an organization are the objectives that it is created to achieve. Where the non-charitable purpose is a necessary ancillary to the charitable one, the trust will not fail. In particular, according to the Charities Act 1993 (section 37): 'charity trustees' means the person having the general control and management of the charity 'trusts' in relation to a charity means the provisions establishing it as a charity and regulating its purposes and administration, whether those provisions take effect as a trust or not, and in relation to other institutions has a corresponding meaning.[7]. [47], Charitable trusts can't be used to promote political changes, and charities attempting such have been "consistently rebuffed" by the courts. Another situation is where the non-charitable element is merely incidental to the main chariatable purpose e.g. Section 1 (1) of the Charities Act 2011 adopts a two-tier definition of a charity. Useful b. Statutes . There is also a requirement that the trust's purposes benefit the public (or some section of the public), and not simply a group of private individuals. (IRC v Baddeley) Know the position of the Charities Commission: o Guidance 2008 o Guidance 2013 o Decisions of importance . As mentioned, charitable trustees have significantly more freedom to act than normal trustees, but the 1993 Act has put restrictions on who may be a charitable trustee. The trusts last referred to are not the less charitable in the eye of the law, because incidentally they benefit the rich as well as the poor, as indeed, every charity that deserves the name must do either directly or indirectly.Lord MacNaghten contrasted the systems of administrative law in England and Scotland: By expounding the Act by analogy, and if you will apply your usual penetration to this point, you will find that there is often no other possible way of making a consistent sensible construction upon statutes conceived in general words, which are to have their operation upon the respective laws of two countries, the rules and forms whereof are different. of Income Taa: Commissioners v. Pemsel involved a trust for missionary purposes in heathen countries, the validity of which waa upheld by the House of Lords. Under the Charities Act 2006 Section 2, thirteen heads of charitable purposes are listed. The charities act 2006 and the charities act 2011. These vary depending on whether the gift that creates the trust is given in life, given after death, or includes land. As with poverty, this category is also found in the 1601 Act's preamble, which refers to charities established for the "Maintenance of Schools of Learning, Free Schools, and Scholars at Universities". The Pemsel Case Foundation is hiring a part-time Executive Director for a two-year renewable period. The courts are willing to accept charitable trusts for recreational activities if they benefit people as a whole, and not just the people covered by Section 1(2)(a), as in Guild v IRC,[46] where Lord Keith stated "the fact is that persons from all walks of life and all kinds of social circumstances may have their conditions of life improved by the provision of recreational facilities of a suitable nature". If the gift is of land and made during the donor's lifetime, it must comply with Section 53(1)(b) of the Law of Property Act 1925, which requires that the agreement be a written document signed by the person giving it. And the converse case may be possible. Once constituted properly, a charitable trust, like all express trusts, cannot be undone unless there is something allowing that within the trust instrument. Hence it would appear that the degree of, between the two purposes have to be looked at. Firstly, the organisation must be capable of having a positive effect and not cause harm to the public and secondly, those eligible to receive benefits must (except in the case of organisation set up exclusively to relieve financial hardship) comprise a large group so as to be considered the public or sufficient section of the community and no personal or private relationships must be used to limit those who may benefit. as Lord Hailsham pointed out in IRC v McMullen5, the law must change as ideas about social values change. A charitable organization or charity is an organization whose primary objectives are philanthropy and social well-being (e.g. Encouraging and facilitating the better administration of charities. .. Subsequent failure cases are designed to have the charity's funds applied to more effective purposes, and as such money already donated to the charity cannot be returned to the next of kin of the original money; in Re Wright,[75] it was said that "once money has been effectually dedicated to charity the testator's next of kin or residuary legatees are for ever excluded". Requirements: a. [66] Under Section 110 of the Act, the Commission is tasked with giving advice or opinions to trustees relating to the performance or administration of their charity. The classification is to be used for a matter of convenience and is not a definition. Cited - Income Tax Special Commissioners v Pemsel HL 20-Jul-1891. [32] Curiously, and individually to religious charities, the public benefit requirement is justified by the assumption that, according to Cross J in Neville Estates v Madden,[33] "some benefit accrues to the public from attendance at places of worship of persons who live in this world and mix with their fellow citizens". The second, laid out in National Anti-Vivisection Society v IRC,[48] is that the courts must assume the law to be correct, and as such could not support any charity which is trying to alter that law. The Revenue appealed against the decision by Foster J that the Council ought to be registered as a charity. The AG argued that the effects . However there is no clear line that the law draws here and thus inconsistencies have occurred. . Max-Josef Pemsel (15 January 1897 - 30 June 1985) was a Generalleutnant in the German Army during Second World War.After the war he became one of the very few senior officers from the Nazi Germany-era armed forces to serve in the West German Army.. .if(typeof ez_ad_units != 'undefined'){ez_ad_units.push([[300,250],'swarb_co_uk-medrectangle-4','ezslot_8',113,'0','0'])};__ez_fad_position('div-gpt-ad-swarb_co_uk-medrectangle-4-0'); Lists of cited by and citing cases may be incomplete. A charitable purpose was determined in the case of IRC v Pemsel (1891). Again, this excludes trusts which isolate the beneficiaries from the public, as in Re Grove-Grady,[38] where the trust sought to provide "a refuge [for animals] so that they shall be safe from molestation and destruction by man". In Bauman v Secular Society 1917 it was held that a society whose predominant aim was not to change the law could be charitable even though it included a subsidiary activity to charge legislation. Basing himself in the Preamble, Lord Macnaghten sought to extract from it a generalised classification of what constitutes charitable in the landmark case Commissioners of Income Tax v Pemsel (1891), which resulted in the following four-fold divisions: Trusts for the relief of poverty Trusts for the advancement of education Trusts for the Trust for relief of property. .Cited Gilmour v Coats HL 1949 Prayers Alone did not make Convent Charitable A trust to apply the income of a fund for all or any of the purposes of a community of Roman Catholic Carmelite nuns living in seclusion and spending their lives in prayer, contemplation and penance, was not charitable because it could not be shown . [3] Charitable trusts are also exempt from many formalities when being created, including the rule against perpetuities. Published: 28th Sep 2021. This definition was expanded on by Slade J in McGovern v Attorney General, where he said that: (1) A trust for research will ordinarily qualify as a charitable trust if, but only if (a) the subject matter of the proposed research is a useful object of study; and (b) if it is contemplated that the knowledge acquired as a result of the research will be disseminated to others; and (c) the trust is for the benefit of the public, or a sufficiently important section of the public. This article questions whether in the area of poor relief equity acts out of a humanitarian regard for those whose relief is the purpose of the trust, or whether there is a more . Before making any decision, you must read the full case report and take professional advice as appropriate. The company should have . The plaintiff (B) was a brewer. Except as provided by the Secretary, a defined contribution plan which is subject to the funding standards of section 412 shall be treated in the same manner as a stock bonus or profit-sharing plan for purposes of this subparagraph . This fourth category allowed for charitable trusts other . The case concerned whether a mistake as to the identity of a contracting party was so fundamental so as to negate the consent of the other party. Section 2(2) (b) is the advancement of education which may be suitable for Lauras second gift. That gifts to be charitable were traditionally classified into four categories known as Pemsel categories, namely: the relief of poverty, the advancement of education, the advancement of religion, and other purposes beneficial to the community: whereas there is a presumption that the first three categories are for the public benefit, such [67], Both the High Court and the Charities Commission are authorised to establish schemes administering charities. There are three tests to be satisfied in order for Lauras gifts to be classed as a charitable purpose. If the money is to be spent on non-charitable purposes, the trust fails, regardless of the fact that it applies to a particular area. Life and career. Such trusts will be invalid in several circumstances; charitable trusts are not allowed to be run for profit, nor can they have purposes that are not charitable (unless these are ancillary to the charitable purpose). Biography. If the gift is given after death through a will, the will must comply with Section 9 of the Wills Act 1837, which requires that the will be in writing and signed by the testator (or somebody else present, at the testator's instruction), it is clear that the testator intended to give effect to the will, and the signature is made or noted by two or more witnesses. [23], For artistic pursuits, it is not enough to promote such things generally, as it is too vague. Before making any decision, you must read the full case report and take professional advice as appropriate. Cited - Incorporated Council of Law Reporting For England And Wales v Attorney-General And Others CA 14-Oct-1971. [65], The jurisdiction of the Charity Commission is concurrent with that of the High Court of Justice. .Cited Incorporated Council of Law Reporting For England And Wales v Attorney-General And Others CA 14-Oct-1971 The Council sought charitable status for its activities of reporting the law. b. The public benefit was central to the validity of trusts which fell into the fourth category in Verge v Somerville (1924) the charitable statues of trusts depend on whether the benefit which they provide are available to the community at large. [62] They can also remove trustees on the grounds of bankruptcy, mental incapacity, failure to act or the trustee's absence from the country. Case law Income Tax Commissioners v Pemsel [1891] Gilmour v Coats McGovern v A-G [1982] Oppenheim v Tobacco Securities Trust Co Ltd [1950] National Anti-Vivisection Society v IRC [1947] Dingle v Turner [1972] Independent Schools Council v Charity Commission [2011] A-G v Charity Commission for England and Wales [2012] . To export a reference to this article please select a referencing stye below: UK law covers the laws and legislation of England, Wales, Northern Ireland and Scotland. [30] This category also covers groups with small followings, as in Re Watson,[31] and with doubtful theology, as in Thornton v Howe. [29] The 2006 Act expanded this, noting that religion "includes.. a religion which does not involve belief in a god". Section 1(1) of the Act, however, preserves the need to provide a "public benefit". N.B. The first of these "sub-categories" contains trusts for the benefit of the sick and old; the Preamble to the 1601 Act gave "aged, impotent and poor people" as acceptable beneficiaries for a charity. Williams v IRC (1947 . [10], Trusts must also be for "public benefit", which was considered at length in Oppenheim v Tobacco Securities Trust. And it contained in the preamble a list of charities so varied and comprehensive that it became the practice of the Court to refer to it as a sort of index or chart. [26] When there is doubt, the courts ignore the opinions of the beneficiary and instead rely on experts, as in Re Pinion. In Pemsel's Case, Lord Macnaghten adopted Romilly's classification system. With the 1960 Act (the relevant provisions of which are now included in the 1993 Act), cy-pres can be applied where the original purposes have: (a)been as far as may be fulfilled; or cannot be carried out, or not according to the directions given and to the spirit of the gift; (b) or where the original purposes provide a use for part only of the property available by virtue of the gift; (c) where the property available by virtue of the gift and other property applicable for similar purposes can be more effectively used in conjunction, and to that end can suitably, regard being had to the spirit of the gift, be made applicable to common purposes; (d) or where the original purposes were laid down by reference to an area which then was but has ceased to be a unit for some other purpose, or by reference to a class of persons or to an area which has for any reason since ceased to be suitable, regard being had to the spirit of the gift, or to be practical in administering the gift; (e) or where the original purposes, in whole or in part, have since they were laid down been adequately provided for by other means; or ceased, as being useless or harmful to the community or for other reasons, to be in law charitable; or ceased in any other way to provide a suitable and effective method of using the property available by virtue of the gift, regarding being had to the spirit of the gift. Lord MacNaghten, in IRC v Pemsel (see above, p 599), classified the charitable purposes, as stated in the preamble to the Charitable Uses Act 1601, as follows: (a) the relief of poverty; (b) the advancement of education; (c) the advancement of religion; (d) other purposes beneficial to the community. However Lord Simmonds in the case of IRC v Baddeley (1955) emphasised that once the benefit of a trust are open to the public or an appreciable section, the trust is deemed to be charitable even if relatively few people take advantage of the benefits. The general principle is that political trusts are not charitable and this position has not been affected by the Charities Act 2006. The Act also excludes private clubs, unless the members fall under Section 1(2)(a). The doctrine originated in ecclesiastical law, the name coming as a contraction of the Norman French cy pres comme possible (as close as possible),[71] and is typically used where the original purpose of the charity has failed, and results in the trust purpose being altered to the nearest realistic alternative. Dingle v Turner. This includes the education of the young, a particularly wide category, described by Lord Hailsham in IRC v McMullen,[20] as "a balanced and systematic process of instruction, training and practice containing both spiritual, moral, mental and physical elements". In addition, it is considered unacceptable for charitable trusts to campaign for political or legal change, although discussing political issues in a neutral manner is acceptable. In Re Hopkins,[22] a gift was given to the Francis Bacon society to find proof that William Shakespeare's plays were written by Bacon. Williams Trustees v IRC [1947] AC 447. IRC v Pemsel Charitable purposes fall into only four categories: relief of poverty, advancement of education, advancement of religion, other purposes beneficial to the community. Instead, the Attorney General of England and Wales sues on behalf of beneficiaries to enforce a charitable trust. Moreover, it appears that if a testator, domiciled in England, leaves property by his will to trustees abroad for charitable purposes abroad the court may . There are a variety of advantages to charitable trust status, including exception from most forms of tax and freedom for the trustees not found in other types of English trust. Wich is second test Lauras gift must pass. The advancement of education clearly covers purposes involving schools and universities but confusion arises when trusts are created for study of esoteric subjects or to advice ideological position which are not annexed to any accepted educational institution. There is also room for organisations to get charitable status even if campaigning is a major part of their work if it is set out appropriately in the governing document e.g. On this Wikipedia the language links are at the top of the page across from the article title. 25% off till end of Feb! [57] The Census of 1861 recorded his occupation as a Commercial Clerk, at Manchester Shipping House. The Philanthropist, Volume 20, No. The point here is as Lord Cross suggested is that there must be some genuine charitable intention on the part of the settlor. This means that trusts for the relief of poverty can be valid, even if only a few people will benefit from the trust; as long as there was a genuine intention to relieve poverty. The legal definition of a charitable organization (and of charity) varies between countries and in some instances regions of the country. Tel: 0795 457 9992, or email david@swarb.co.uk. [40] This can apply even when the class "fluctuates", such as in Re Christchurch Inclosure Act,[41] where a gift was for the benefit of the inhabitants of a group of cottages, whoever those inhabitants might be. [65] The Commission, under Section 29 of the 2011 Act, also keeps the register of charities. swarb.co.uk is published by David Swarbrick of 10 Halifax Road, Brighouse, West Yorkshire, HD6 2AG. the statute proclaims its origin and speaks the language of the English lawyer, with some Scottish legal phrases thrown in rather casually. The law is absolutely clear on this, however the inconsistencies have occurred in the application of the law. In the latter but not the former case the reference to non-charitable activities will deprive the trust of its charitable status. 38 Requirement that there be a net benefit for the public Held: The prisoner had followed through his rights to . [77] This is because gifts to an unincorporated body must be treated as gifts to that body's purpose, not to the body itself, since unincorporated bodies cannot hold property. These general views will probably always be taken from the language or style of one of these countries more than from the other, and not correspond equally with the genius or terms of both laws. Held: A gift . The Act also lays out what kinds of activities are in the "interest of social welfare", stating in Section 1(2) that it is where the facilities "are provided with the object of improving the conditions of life for the persons for whom the facilities are primarily provided" and in Section 1(2)(a) "those persons have need of such facilities as aforesaid by reason of their youth, age, infirmity or disablement, poverty or social and economic circumstances", or where, in Section 1(2)(b) "the facilities are available to members of the public at large". As mentioned, the Attorney General represents the beneficiaries as a parens patriae, appearing on the part of The Crown. Facts. [27] This area is covered by the Charities Act 2006, which lists "the advancement of citizenship or community development" and "the advancement of the arts, culture, heritage or science" as valid types of charitable trust. This contention was, in my opinion, rightly rejected both by Mr. Justice Harman and the Court of Appeal. Pemsel [1891] A.C. 531. :- My Lords, in this case the Income Tax Commissioners have appealed against an order of the Court of Appeal, whereby a peremptory mandamus was awarded against them, commanding them to make [] A Notice of Reference dated 27 January 2011 was made by Her Majesty's Attorney General following concerns expressed by the Charity Commission that the Charities Act 2006 (2006 Act) had cast doubt on the continued charitable status of certain charitable trusts. This extends to the support of religious buildings and sick or old members of the clergy, as in Re Forster. J and P M Dockeray (A Firm) v Secretary of State for the Environment, Food and Rural Affairs: Admn 18 Mar 2002, EB (Kosovo) v Secretary of State for the Home Department: HL 25 Jun 2008, Income Tax Special Commissioners v Pemsel, British Airways Plc v British Airline Pilots Association: QBD 23 Jul 2019, Wright v Troy Lucas (A Firm) and Another: QBD 15 Mar 2019, Hayes v Revenue and Customs (Income Tax Loan Interest Relief Disallowed): FTTTx 23 Jun 2020, Ashbolt and Another v Revenue and Customs and Another: Admn 18 Jun 2020, Indian Deluxe Ltd v Revenue and Customs (Income Tax/Corporation Tax : Other): FTTTx 5 Jun 2020, Productivity-Quality Systems Inc v Cybermetrics Corporation and Another: QBD 27 Sep 2019, Thitchener and Another v Vantage Capital Markets Llp: QBD 21 Jun 2019, McCarthy v Revenue and Customs (High Income Child Benefit Charge Penalty): FTTTx 8 Apr 2020, HU206722018 and HU196862018: AIT 17 Mar 2020, Parker v Chief Constable of the Hampshire Constabulary: CA 25 Jun 1999, Christofi v Barclays Bank Plc: CA 28 Jun 1999, Demite Limited v Protec Health Limited; Dayman and Gilbert: CA 24 Jun 1999, Demirkaya v Secretary of State for Home Department: CA 23 Jun 1999, Aravco Ltd and Others, Regina (on the application of) v Airport Co-Ordination Ltd: CA 23 Jun 1999, Manchester City Council v Ingram: CA 25 Jun 1999, London Underground Limited v Noel: CA 29 Jun 1999, Shanley v Mersey Docks and Harbour Company General Vargos Shipping Inc: CA 28 Jun 1999, Warsame and Warsame v London Borough of Hounslow: CA 25 Jun 1999, Millington v Secretary of State for Environment Transport and Regions v Shrewsbury and Atcham Borough Council: CA 25 Jun 1999, Chilton v Surrey County Council and Foakes (T/A R F Mechanical Services): CA 24 Jun 1999, Oliver v Calderdale Metropolitan Borough Council: CA 23 Jun 1999, Regina v Her Majestys Coroner for Northumberland ex parte Jacobs: CA 22 Jun 1999, Sheriff v Klyne Tugs (Lowestoft) Ltd: CA 24 Jun 1999, Starke and another (Executors of Brown decd) v Inland Revenue Commissioners: CA 23 May 1995, South and District Finance Plc v Barnes Etc: CA 15 May 1995, Gan Insurance Company Limited and Another v Tai Ping Insurance Company Limited: CA 28 May 1999, Thorn EMI Plc v Customs and Excise Commissioners: CA 5 Jun 1995, London Borough of Bromley v Morritt: CA 21 Jun 1999, Kuwait Oil Tanker Company Sak; Sitka Shipping Incorporated v Al Bader;Qabazard; Stafford and H Clarkson and Company Limited; Mccoy; Kuwait Petroleum Corporation and Others: CA 28 May 1999, Worby, Worby and Worby v Rosser: CA 28 May 1999, Bajwa v British Airways plc; Whitehouse v Smith; Wilson v Mid Glamorgan Council and Sheppard: CA 28 May 1999.
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