LandmarkChancery Division[1962] Ch 8321 Jan 1962· Equity & Trusts
Cross J classified gifts to unincorporated associations in three ways: as absolute gifts to present members, as gifts to members subject to their contractual obligations under the association's rules, or as trusts for the association's purposes, valid only if those purposes are charitable. He held the Catford Synagogue's land was held on a valid charitable trust. The case laid groundwork for the contract-holding theory.