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[1913] 1 Ch 9. A woman entered into amarriage settlement which contained a covenant to transfer certain property acquired after the marriage into a Trust for the benefit of her children. She received £250, which she put into bonds in her husband's name, rather than transferring to the Trustees. When the husband died, the trustees sued his estate to recover the money for the trust. The question that arose was: when the trust of the £ properly constituted -- when the wife received the money, or when the trustees received it on the order of the court? Clearly there had been no transfer of the legal title to the trustees up until the court action (see constitution of trusts). If the trust was not constituted until the husband died, then the beneficial interest in the money (and interest payments thereon) would not have been available to the beneficiaries until then. However, if the trust was constituted at the moment the wife received the property, then any benefits following from that money properly belonged to the beneficiaries of the trust.

The court decided that the trust was constituted the moment the wife received the money, despite there being no transfer of the legal title until later. Equity, it was said, treats as done that which ought to be done. Clearly the transfer to the trustees ought to have been done much earlier.

See also re plumptres marriage settlement (1910).