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[1993] 1 WLR 934, aff'd [1994] 1 WLR 452, CA. The defendant made an oral declaration of trust regarding 50 company shares in favour of the claimant, and then attempted to disavow his declaration. The claimant subsequently sued for his 50 shares. Before the court, the defendant argued that his declaration was effectively void for insufficient certainty of subject matter; he had not specified which 50 of his 950 shares were subject to the trust. The Court of Appeal ultimately held that, in general, a trust is certain if immediately after its declaration a court could make an order to enforce it. In this instance, it was irrelevant which 50 of the shares were the subject of the trust. The original decision was therefore upheld.

See also Certainty of subject matter.