Beneficiary Principle and Purpose Trusts

Definition: A purpose trust is created for a specific cause rather than for the benefit of individuals.
General Rule of Invalidity: As a general rule, private trusts for purposes are invalid; they must be for the benefit of individuals to satisfy the beneficiary principle.
Charitable Status: If a purpose trust is valid, it is generally regarded as charitable in nature.

The Beneficiary Principle: Established in Morice v Bishop of Durham $(1804)$ , trusts require beneficiaries with locus standi to enforce them. To be valid, a trust cannot be for an abstract or intangible purpose that leaves no one to hold trustees accountable.
Certainty of Purpose: Purposes must be clear and certain for court enforcement. In Re Astor’s Settlement Trusts $[1952]$ , the court noted that non-charitable purposes must be stated in phrases embodying definite concepts.
Wording Issues: In Re Gibbons $[1917]$ , the phrase "to my best spiritual advantage" was found too vague. Similarly, Re Endacott $[1960]$ failed because the goal of providing a "useful memorial to myself" was not sufficiently specific.

The Perpetuity Period: A trust is void if interests might vest outside the perpetuity period.
Lives in Being: This usually refers to human lives relevant to the disposition. If no life is specified, the period is limited to $21$ years.
Northern Ireland Legislation: The Perpetuities Act (NI) $1966$ allows a settlor to specify a period up to $80$ years. If no period is specified, it remains $21$ years.
England and Wales Comparison: The Perpetuities and Accumulations Act $2009$ extended the period to $125$ years, but this does not apply to Northern Ireland.
Rule Against Inalienability: Also known as the rule against perpetual trusts, this prevents property from being tied up and untransferable beyond the perpetuity period.

Erection vs. Maintenance: In Mussett v Bingle $[1876]$ , a bequest to erect a monument was upheld, but a second fund for its perpetual maintenance failed for offending the rule against perpetuities.
Standard Time Limits: Gifts for grave maintenance are often limited to the legal maximum. In Pirbright v Salwey $[1896]$ and Re Hooper $[1932]$ , phrases like "as far as they can legally do so" resulted in the trusts being valid for exactly $21$ years.
Churchyards: A gift for the maintenance of an entire churchyard is valid as a charitable gift (Re Vaughan $(1886)$ ).

Charitable vs. Non-Charitable: General trusts for animals are charitable. Trusts for specific animals are non-charitable but can be valid as "trusts of imperfect obligation."
Notable Cases: * Pettingall v Pettingall $(1842)$ : Valid gift of $£50$ per year for a favorite black mare. * Re Dean $(1889)$ : Valid gift of $£750$ per year for horses and hounds for $50$ years.
Limit on Duration: In Re Kelly $[1932]$ , the court ruled that animal lives are not "lives in being." Consequently, such trusts are only valid for a period of $21$ years.

Definition: As per Conservative and Unionist Central Office v Burrell $[1982]$ , these are groups bound by mutual duties and rules for common non-business purposes but lacking separate legal personality.
Indirect Benefit: Re Denley’s Trust Deed $[1969]$ suggests the beneficiary principle can be overcome if a purpose trust provides a direct or indirect benefit to individuals, granting them locus standi to enforce the trust.