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'The judicial approach to establishing the three certainties should be reconsidered. They should remain very strict when it comes to establishing certainty of intention. But

'The judicial approach to establishing the three certainties should be reconsidered. They should remain very strict when it comes to establishing certainty of intention. But once they are satisfied that an express trust was intended, the courts should be more pragmatic in terms of their willingness to find certainty of subject matter and of object, taking into account the context'

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