An appointment after the deaths of any objects of the power to their next of kin is valid in the case of an object alive at the creation of the power, subject to the question whether the next of kin are objects of the power, but is invalid under the rule against perpetuities in the case of an object unborn at the creation of the power1.
In relation to special powers under instruments to which the Perpetuities and Accumulations Act 1964 applies2, or instruments to which the Perpetuities and
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