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[1910] 1 Ch 609. Amarriage settlement is subject to somewhat anomalous enforcement provisions, compared to most other forms of Trust. In particular, the Trustees have standing -- indeed they have a duty -- to enforce the terms of the settlement against the settlor. If the settlor has covenanted to transfer certain property to the trust, then the trustees can seekspecific performance of that obligation, despite themselves having offered no consideration; the covenant as a whole is subject to 'marriage consideration'.

In this case, the terms of the trust were that the settlor's next of kin were to take certain benefits of the trust in the event that the settlor had no children. As it turned out, the settlor had no children, but he did have property that he ought to have placed into the trust. The next of kin sued the settlor for specific performance, to compel him to transfer the property and constitute the trust (see constitution of trusts).

The action failed. While the children of the marriage, had there been any, could have enforced the covenant -- despite offering no valuable consideration of their own -- the next of kin had offered no consideration, and were not within the marriage consideration. In short, just because the trust was a marriage settlement, that did not mean that the usual limitation on enforcement of covenants were completely set aside.