Commentary

62 Meaning of ‘advancement or benefit’

POWERS OF APPOINTMENT vol 33
| Commentary

62 Meaning of ‘advancement or benefit’

| Commentary

62 Meaning of ‘advancement or benefit’

What do the words ‘advancement or benefit’ mean? According to Lord Radcliffe in Pilkington v IRC1 the word ‘advancement’ originally meant the establishment in life of the beneficiary who was the object of the power. In the nineteenth century this meant buying an apprenticeship or the purchase of a commission in the army or an interest in business. In the case of women there could be advancement on marriage. In Pilkington v IRC, Lord Radcliffe made the important point that the word ‘advancement’ does not carry with it the idea of paying money to

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