Hobourn Aero Components Limited’s Air Raid Distress Fund: CA 2 Jan 1946

The trust sought charitable exemption for sums collected voluntarily from workers in a munitions factory for the benefit of co-workers who had suffered in the Blitz. The judge had found the trusts not to be charitable.
Held: The appeal failed. Lord Greene MR: ‘The point to my mind which really puts this case beyond reasonable doubt is the fact that a number of employees of this company, actuated by motives of self-help, agreed to a deduction from their wages to constitute a fund to be applied for their own benefit without any question of poverty coming into it. Such an arrangement seems to me to stamp the whole transaction as one having a personal character, money put up by a number of people, not for the general benefit, but for their own individual benefit.’ Morton, L.J., as he then was, said (p. 209): ‘ Those eligible to receive benefits were not even all the employees of the particular company. They were those who chose to join in the scheme.’

Judges:

Lord Greene MR

Citations:

[1946] 1 Ch 194, [1946] 1 All ER 501, [1946] Ch 194

Jurisdiction:

England and Wales

Citing:

Appeal fromHobourn Aero Components Limited’s Air Raid Distress Fund 1946
Voluntary collections from employees of the munition factories belonging to a certain company were to be used to relieve without a means test the distress suffered by the employees from air raids.
Held: This was not a charity. . .

Cited by:

CitedInland Revenue Commissioners v Glasgow Police Athletic Association HL 9-Mar-1953
The House was asked whether the taxpayer association was established for ‘Charitable purposes only’ so as to benefit from tax exemptions. The association promoted sporting activities among members of the Glasgow police.
Held: Though the . .
Lists of cited by and citing cases may be incomplete.

Charity

Updated: 23 March 2022; Ref: scu.251603