What is the ratio in Re Coulthurst?

The ratio is that educational trusts must benefit a sufficient section of the public to be charitable, and cannot be restricted to employees of a particular company or their relatives as this creates too narrow a class.

What did the court decide in Re Coulthurst?

The Court of Appeal decided that a scholarship trust restricted to descendants of company employees was not charitable because the beneficiary class was too narrowly defined.

Why is Re Coulthurst important for charity law?

It demonstrates the stricter public benefit requirements applied to educational charities compared to poverty trusts, and helps define what constitutes a sufficient section of the public for charitable purposes.

What is the ratio in Re Coulthurst?

The ratio is that educational trusts must benefit a sufficient section of the public to be charitable, and cannot be restricted to employees of a particular company or their relatives as this creates too narrow a class.

What did the court decide in Re Coulthurst?

The Court of Appeal decided that a scholarship trust restricted to descendants of company employees was not charitable because the beneficiary class was too narrowly defined.

Why is Re Coulthurst important for charity law?

It demonstrates the stricter public benefit requirements applied to educational charities compared to poverty trusts, and helps define what constitutes a sufficient section of the public for charitable purposes.

Equity & Trusts1 min read

Re Coulthurst

[1951] Ch 661Court of Appeal1951

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“Educational trusts must benefit sufficient section of public, not just company employees' relatives.”

Facts

A trust was established to provide scholarships at specified universities for descendants of employees of a particular company. The trust deed restricted eligibility to children and descendants of employees of the company. The question was whether this educational trust could be charitable given the restricted class of beneficiaries.

Issues

Whether an educational trust restricted to descendants of employees of a particular company satisfied the public benefit requirement necessary for charitable status.

Held

The Court of Appeal held that the trust was not charitable because the class of beneficiaries was too narrowly defined and did not constitute a sufficient section of the public.

Significance

This case is crucial for understanding the public benefit requirement in educational charities and demonstrates the different standards applied across different categories of charitable purpose. It remains important for practitioners drafting educational trusts and scholarships.

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OSCOLA Citation

Re Coulthurst [1951] Ch 661 (CA)

Equity and TrustsCharity LawAdvancement of EducationPublic Benefit

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