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[1958] 1 All ER 254n (CA). A testamentary gift to set up an organization to carry out research into a new 40-letter alphabet for English was held, narrowly, not to create a validcharitable trust. In general, research and scholarly organizations can be valid charities, falling within the 'advancement of education' category ofpemsels case (1891). However, Shaw seems to have failed because the didactic benefits of his project were not entirely clear. What does seem clear, however, is that heard on a different day by different judges, the decision might have gone the other way. This case serves to illustrate the difficulty of providing a precise legal definition of 'charity'.