... a man will seek to benefit his fellow men2." This suggests that the courts will generally find a purpose trust to be charitable wherever possible and will avoid consequences of invalidity. This in effect proposes that the definition of 'charitable purpose' has and will be broadened over the years. It is, however, important to note that there is another aspect to the definition of 'charitable purpose'. The second aspect concerns fiscal privileges, which provides the threshold for tax relief. In Commissioners for Special Purposes of the Income Tax v Pemsel3 (Pemsel's case), the judgment of Lord MacNaughten embedded the four categories of charitable heads into law. Theses were trusts for the relief of poverty; trusts for the advancement of education or religion; and trusts for all other purposes beneficial to the community. The Pemsel's case held that for the purposes of exemption from income tax the definition of 'charitable purpose' should ...

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