 Equity has been willing to accept their validity in the common law to prevent the trustee committing fraud and keeping the property; justifications for this acceptance are debated.In practical terms, there are several reasons why admitting the language of fraud to justify a fully secret trust, but not a half-secret trust, would be sub-optimal.This is considered one principal reason why the court in "Blackwell v Blackwell" established that both types of secret trust shared a single justification.