West Yorkshire Metropolitan County Council v. (1986)

Key Notes

• Facts: The case concerned a trust established for the benefit of any or all of the inhabitants of West Yorkshire County. The large and undefined class of beneficiaries raised the issue of whether such a trust could be validly administered.

• Outcome: The court invalidated the trust, applying an "administrative unworkability" test due to the vast and unspecified number of beneficiaries.

• Reasoning: Lloyd LJ emphasised the unworkability of managing a trust for such a large class of beneficiaries, noting the practical difficulties in identifying individuals and distributing the trust’s assets. The size of the class and the fund were significant factors in this determination.

Impact & Analysis

• Administrative Unworkability Test: The case established that a trust could fail on the grounds of administrative unworkability, especially if the number of beneficiaries is so large that it becomes impractical to manage. The size of the class and the trust fund both play a role in this assessment.

• Proportionality of Size and Fund: The decision indicated that the size of the trust fund could influence the court's decision on whether a trust for a large number of beneficiaries is administratively feasible. For example, if the fund was significantly larger (e.g., £50 million), the trust might still fail if the class size was vast.

• Limitations on Trusts for Non-Charitable Purposes: The court’s ruling also suggested a limitation in English law against creating trusts for non-charitable purposes that aim to achieve broad, uncertain goals, like disseminating information on political issues (as in this case, the abolition of Metropolitan County Councils). This aligns with broader public policy concerns about the validity of non-charitable trusts.