It is a commonplace that ‘Equity will not assist a volunteer’, or ‘Equity will not perfect an imperfect gift’. One problem posed by this rule is the question: what is the attitude of equity to instruments which, though not effective at law to transfer property, may at law give the volunteer beneficiary, or a person named as a trustee for volunteers, a right of action in damages? This is the very well-trodden ground of covenants to settle property and Re Pryce, Re Kay’s Settlement, and Re Cook’s Settlement Trusts, and the apparent conflict between these cases and Fletcher v Fletcher and Re Cavendish-Browne’s Settlement Trusts.