Ratio Decidendi
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.
ข้อเท็จจริง
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.
สรุปคำพิพากษา
The court held that Vautier, being sui juris and solely and absolutely entitled, could call for the trust property immediately, overriding the testator's direction to wait until age 25.
คำกล่าวสำคัญ
"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
การอ้างอิงภายหลัง
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].