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[1865] 1 Ch App 25. A man took a cheque that was made out to him and placed it in the hands of his infant son, saying This is for baby. He then took the cheque and put it away, intending to make it over to a bank account in his son's name in due course. However, he died before he could effect the payment. The question arose whether this man had made a gift of the money to his son.

The court held that he had not done so, and the money therefore passed to his estate to be dealt with by his executors.

According to milroy v lord (1862), a gift can be made by outright transfer of the legal title, or the creation of a trust. In this case the donor had failed to take the necessary steps to divest himself of the legal title, and the court was unwilling to rescue the gift by assuming the creation of a trust.

See also imperfect gift.