판결 이유
A beneficiary who is of full age and capacity and is absolutely entitled to trust property can call upon the trustee to transfer the property to them, even if the trust instrument provides for a later date of distribution.
사실관계
A testator left stocks to trustees to accumulate income and pay the capital and accumulated income to Vautier when he reached 25. Vautier, upon reaching 21 (the age of majority), demanded the property.
판결 요약
Lord Langdale MR held that where a legatee has an absolute, vested, and indefeasible interest in property, a direction merely postponing enjoyment (here, until the beneficiary reached 25) is treated as being for the benefit of that beneficiary alone and does not prevent them from calling for the property once of full age and capacity. Vautier, being sui juris and solely and absolutely entitled to both the accumulated income and the capital, could therefore require the trustees to transfer the fund to him immediately, notwithstanding the testator's direction to accumulate until he was 25. The principle — that a beneficiary (or beneficiaries together) who are absolutely entitled and all of full age and capacity may collapse the trust and direct the trustees, overriding the settlor's wishes as to timing — is now known as the rule in Saunders v Vautier.
주요 인용문
"Where a legacy is directed to accumulate for a certain period, or where the payment is postponed, the legatee, if he has an absolute indefeasible interest, is not bound to wait until the expiration of that period."
— Lord Langdale MR
후속 처리
Foundational principle of trust law. Extended to groups of beneficiaries acting together (all must be ascertained, of full age, and consenting) by Re Smith [1928].
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