R v District Auditor ex p West Yorkshire Metropolitan County...

Facts

• The case involved a discretionary trust created by West Yorkshire Metropolitan County Council intended to benefit all residents of West Yorkshire, totaling over two million people.
• The trust defined its intended beneficiaries as the population of West Yorkshire.
• The trustees would have been required to consider the interests of an extremely large group, raising concerns about manageability.
• The adequacy of trust aims, assets, and identifiable beneficiaries in line with valid trust requirements was addressed.
• The dispute focused on whether the sheer size of the beneficiary group made the trust unworkable.

Issues

1. Whether a trust benefiting an extremely large and defined class of beneficiaries (all West Yorkshire residents) is administratively workable.
2. Whether the certainty of objects requirement, satisfied by a clear definition of beneficiaries, can be separately overridden by concerns about practical administration.
3. Whether a trust can be invalidated solely on the ground of administrative unworkability, regardless of conceptual certainty or evidential certainty of membership.

Decision

• The court held that the trust was administratively unworkable due to the sheer number of beneficiaries (over two million people), rendering it impossible for trustees to carry out their duties.
• It was found that a group of this magnitude made the operation of the trust unfeasible and resulted in the trust being invalid.
• The decision established that administrative unworkability is a distinct ground for invalidating a trust, separate from issues of vague or uncertain beneficiary definitions.

Legal Principles

• Administrative unworkability provides an independent basis for invalidating a trust where the size or structure makes it impossible for trustees to adequately manage and fulfill its objectives.
• Certainty of objects requires trustees be able to identify beneficiaries, but this alone does not guarantee validity if the class is impractically large.
• The difference between conceptual certainty (clear boundaries of the group) and evidential certainty (ability to prove membership) was emphasized; administrative unworkability may arise even when both are satisfied.
• The case affirms that practical management is essential in upholding trust structures regardless of conceptual clarity.

Conclusion

R v District Auditor ex p West Yorkshire Metropolitan County Council [1986] confirmed that, while trusts must have clearly defined aims, assets, and beneficiaries, administrative feasibility remains an additional and essential requirement; a defined class can nonetheless invalidate a trust if its size renders management impractical.