 Under the rule of three uncertainties in private trust, half or fully secretly trust ought to fail because of lack of intentional element.Those in favour of its enforcement must therefore observe the imposition of resulting trust as required under three certainties rule, and the "fraud" theory seems insufficient to do so, since there is no sublet and significant impact for dishonest act and if otherwise fraud can be upheld; and therefore no conduct on the part of the trustee to warrant it.The deceased's intended disposition remains imperfectly constituted and the intended beneficiary's claim is thus weaker than the residuary legatee's.