IRC v Baddeley
A trust for the religious, social and physical wellbeing of Methodists in a particular area was not charitable, because it was for a class within a class and included non charitable purposes.
Facts
Land was held on trust for the promotion of the religious, social and physical wellbeing of persons resident in West Ham and Leyton who were, or were likely to become, members of the Methodist Church, by providing facilities for religious services and instruction, and for social and physical training and recreation. The trustees claimed that the trust was charitable, so that a conveyance of land to it was exempt from stamp duty.
Legal principle
The House of Lords held that the trust was not charitable. Viscount Simonds said that, for a trust falling under the fourth head of purposes beneficial to the community, the beneficiaries must be the community as a whole, or a sufficient section of it, and not a class within a class, such as residents of an area who were also members of a particular church. The purposes also included social activities, which were not charitable. The decision led to the Recreational Charities Act 1958.
Related cases on charitable trusts
- Chichester Diocesan Fund and Board of Finance Inc v Simpson [1944] AC 341
- Re Compton [1945] Ch 123
- Dingle v Turner [1972] AC 601
- Re Finger's Will Trusts [1972] Ch 286
- Gilmour v Coats [1949] AC 426
- Re Harwood [1936] Ch 285
- Re Hetherington [1990] Ch 1
- Income Tax Special Purposes Commissioners v Pemsel [1891] AC 531
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