Ratio Decidendi
A trust for the advancement of education must benefit a sufficient section of the public to be charitable. A trust limited to the children of employees of a particular company is not charitable because the beneficiaries are defined by a personal relationship (employment) rather than a public characteristic.
ข้อเท็จจริง
A trust was established to provide for the education of children of employees and former employees of British-American Tobacco Co Ltd. There were over 110,000 employees, but the beneficiaries were limited to those connected with the company by employment.
สรุปคำพิพากษา
The House of Lords held the trust was not charitable. Although the potential class of beneficiaries was large, they were connected by a personal relationship (employment) rather than by any characteristic that identified them as a section of the public. The trust therefore failed the public benefit requirement.
คำกล่าวสำคัญ
"A group of persons may be numerous but, if the nexus between them is their personal relationship to a particular individual or company, they do not constitute a section of the public."
— Lord Simonds
การอ้างอิงภายหลัง
Remains the leading authority on the 'personal nexus' test for public benefit.
Applied in Dingle v Turner regarding trusts for employees' dependants.