 If this is the case, the next-of-kin would be obliged to hold the property on trust and fulfil the dying person's wishes.A secret trust must be contrasted with merely placing a moral obligation upon the beneficiary to deal with the legacy in particular way (as in "Re Snowden") and must impose a binding obligation, without discretion to act within its terms or not.The secret trust has proved difficult to reconcile with Section 9 of the Wills Act 1837, which provides that a will is only valid when