law jurisdictions. Decorations Lord Macnaghten was made a Knight Grand Cross of the Order of St Michael and St George in 1902 and a Knight Grand Cross of the Order of the Bath in the 1911 coronation honours of George V. He also succeeded his elder brother, Francis, as fourth Baronet in the latter year. Legacy Lord Macnaghten's most famous contribution to English law was the determination of categories of charitable trusts (in the case of Commissioners for Special Purposes of Income Tax v Pemsel). He also sat in the landmark decision of Salomon v A Salomon & Co Ltd. In the case of Montgomery v Thompson (Eng.), AC 225 (1891), he held that a brewery opened in the town of Stone in Staffordshire could not use the name "Stone Ale", as this would infringe the rights of an existing seller of a product named "Stone Ale". He famously remarked, "Thirsty folk want beer, not explanations." He is famous for the elegance of his prose. An example is given in the case of Gluckstein v Barnes [1900] AC 240, where he refused to order that fraudulent company promoters should be entitled to contribution from other participants of the fraud. He said, "In these two matters Mr. Gluckstein has been in my opinion extremely fortunate. But he complains that he may have a difficulty in recovering from his co-directors their share of the spoil, and he asks that the official liquidator may proceed against his associates before calling upon him to make good the whole amount with which he has been charged. My Lords, there may be occasions in which that would be a proper course to take. But I cannot think that this is a case in which any indulgence ought to be shewn to Mr. Gluckstein. He may or may not be able to recover a contribution from those who joined with him in defrauding the company. He can bring an action at law if he likes. If he hesitates to take that course or takes it and fails, then his only remedy lies in an appeal to that sense of honour which is popularly supposed to exist among robbers of a humbler type." He also gave an eloquent description of a floating charge in Illingworth v Houldsworth [1904] AC 335, where he said, "A specific charge, I think, is one that without more fastens on ascertained and definite