... rule of law, not permitting much argument or exception which led to harsh and seemingly paradoxical results but that equity has tampered the wind to the shorn lamb." In accordance we must assess how the wind changed the position of volunteers. This consequently leads to the question; has there been a shift in the policy of the courts or has there been the establishment of a new equitable principle? The law prior to Pennington v Waine [FN1]; can be said to be 'tolerably clear.'[FN2] The law of perfect gifts and perfectly constituted trusts stems form the much sighted statement by Turner LJ in Milroy v Lord [FN3]: "...in order to render a voluntary settlement valid and effectual, the settler must have done everything which, according to the nature of the property comprised in the settlement, was necessary to be done in order to transfer the property and render the settlement binding upon ...

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