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[1972] AC 601 (HL). A Trust to benefit a company's poorer employees was held to be charitable (see charitable trust), despite the strong, but much criticised, message ofoppenheim v tobacco securities trust co (1951). Oppenheim is generally taken to have decided (at least for educational trusts) that apublic purpose trust can not exist where there is a 'personal nexus' between the donor and the beneficiaries.

Unfortunately -- so far as clarity of the law is concerned -- the House decided that this trust was valid because it was for the relief of poverty, and such a trust is not subject to the same test for public benefit. So remarks that Oppenheim should not be applied, although unanimous, have to be regarded as obiter_.