Ratio Decidendi
A trust for the relief of poverty among employees of a particular company can be charitable, because trusts for the relief of poverty have always been treated more favourably regarding public benefit than trusts for other purposes.
ข้อเท็จจริง
A company established a trust to provide pensions for poor employees. The question was whether this was charitable, given that the beneficiaries were defined by their employment relationship with the company (which would fail the Oppenheim test).
สรุปคำพิพากษา
The House of Lords held that the trust was charitable. Trusts for the relief of poverty have historically been treated as an exception to the strict public benefit rules. The personal nexus test from Oppenheim does not apply with the same rigour to poverty relief trusts.
คำกล่าวสำคัญ
"The law has always made a distinction between poverty trusts and other trusts... the personal nexus test has not been applied with the same strictness to trusts for the relief of poverty."
— Lord Cross
การอ้างอิงภายหลัง
Confirms the special treatment of poverty-relief trusts regarding public benefit.