Issue One: The second prerequisite was summarized by Lindley LJ in Allcard v Skinner (supra) at page 185:

Issue One: The second prerequisite was summarized by Lindley LJ in Allcard v Skinner (supra) at page 185:

"But if the gift is so large as not to be reasonably accounted for on the ground of friendship, relationship, charity or other ordinary motives on which ordinary men act, the burden is upon the donee to support the gift."

In adopting the same approach Lord Scarman in National Westminster Bank v Morgan (supra) expressed the view that manifest disadvantage to the complaining party must be shown before a transaction will be set aside for undue influence. Lord Nicholls in Royal Bank of Scotland v Etridge (No.2) (supra) at 461 labelled manifest disadvantage as causing difficulty and giving rise to misunderstanding because the label manifest disadvantage is being applied and understood in a way which does not accord with the meaning intended by Lord Scarman.

Question:

Can you please clarify on this issue