 Therefore, to refer to an arrangement as "dehors" the Wills Act because it is not a prima facie reference to the document is incorrect.The response has been to view the secret trust as a disposition "inter vivos" ("between the living") rather than testamentary under exception.Although the testator is unlikely to consider the trust having come into existence at the time of the will upon his death, whether a disposition is arguably though less convincingly regarded as an "inter vivos" is a question for the courts as well as parliament.