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RECTIFICATION

Carl Islam Barrister TEP

Averose Chancery Chambers

Tel: +44 (0) 116 271 8464

Mob: 0795 812 1530

carl@ihtbar.com

www.ihtbar.com

May 2014

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My services

Trusts

Wills

The statutory remedy

Clerical error

Failure to understand instructions

Approach of the court

Civil procedure

My services

I am a registered Public Access practitioner who can be instructed directly by

members of the public (including executors and trustees) without the

involvement of a solicitor. I am licensed to exercise rights of audience in all

courts and proceedings in England and Wales, and specialise in:

estate planning, trusts, and drafting tax-efficient wills;

inheritance, professional negligence, and tax disputes (including

mediation advocacy); and

construction and rectification of wills.

To arrange an initial fixed fee meeting to discuss your case please send an

email to carl@ihtbar.

Trusts

The equitable jurisdiction to rectify trust instruments is part of equity’s wider

power to relieve against the consequences of a mistake, Day & anor v Day

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[2013] (Court of Appeal). The following general principles were enunciated in

Ashcroft v Barnsdale [2010]:

the distinction between a mistake as to the ‘meaning’ or ‘effect’ of a

document (which may be amenable to rectification) and one as to its

‘consequences’ (which is not) applies to all claims for rectification;

it is not limited to cases involving voluntary transactions;

the relevance of the distinction does not depend upon the nature of the

document which it is sought to rectify;

the function of rectification is to enable the Court to put the record

straight by correcting a mistake in the way in which the parties have

chosen to record their transaction;

it does not empower the Court to change the substance of that

transaction or to correct an error in the transaction itself;

so long as a mistake relates to the meaning or effect of a document

(rather than the ‘consequences’ of, or the ‘advantages’ to be gained

from entering into it), relief may be available even though the actual

words of the document were deliberately adopted by the parties;

it is firmly established that the fact that the parties intended to use a

particular form of words in the mistaken belief that it was achieving

their common intention does not prevent the Court from giving effect

to their true intention;

where the mistake results from the inadvertent omission of a word or

phrase from a document, and it is sought to introduce additional words

into the document to cure that mistake, it may in practice prove easier

to discharge the evidential burden of establishing the existence of a

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mistake than in the case where words have been inadvertently included

in the document which it is sought to rectify;

this is because the parties may not always appreciate the legal effect of

the omission of particular words;

it may be more difficult for parties outwardly to express an intention to

include a word or phrase when they have failed to appreciate the need

for them;

the Court cannot rectify a document merely because it fails to achieve

the fiscal objectives of the parties to it;

a mere misapprehension as to the tax consequences of executing a

particular document will not justify an order for its rectification;

the specific intention of the parties as to how the fiscal objective was to

be achieved must be shown if the Court is to order rectification;

the Court will only order the rectification of a document if it is satisfied

by cogent evidence (sufficient to counteract the effect of the parties’

subscription to the relevant document) that:

1. the document does not give effect to the true agreement or

arrangement between the parties; and

2. there is ‘an issue capable of being contested’ between the

parties, it being irrelevant that rectification of the document is:

(a) sought or consented to by all of them;

(b) desired because it has beneficial fiscal consequences; and

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conversely, the Court will not order rectification if the parties’ rights will

be unaffected, and if the only effect of the order will be to secure a fiscal

benefit for one or more of them.

Wills

Where a testator includes words in his will, having intended to write other

words, they will be omitted from probate. Similarly, if words are included that

were not known or approved, they will also be omitted. If a Court is satisfied

that the will of a testator who died on or after 1 January 1983 is so expressed

that it fails to carry out the testator’s intentions, in consequence of:

(a) a clerical error; or;

(b) a failure to understand his instructions,

it may order that the will be rectified so as to carry out his intentions, s.20(1)

Administration of Justice Act 1982 (the ‘Statutory Remedy’).

Not every negligently drafted will is capable of rectification and the remedy is

not available where the draftsman’s error is one of legal understanding. The

distinction between, ‘clerical error’ and ‘an error made in carrying [the

testator’s] intentions into effect by the drafter’s choice of words’ marks a

boundary beyond which the disappointed beneficiary’s remedy lies in

negligence and rectification is not available,’ Wordingham v Royal Exchange

Trust Company [1992].

‘[It] should be borne in mind that the remedy of rectification is available to

correct mistakes in the expression of the testator’s intentions, and not for lack

of vision, perception or knowledge. One cannot look at circumstances that were

not foreseen by the testator at the time he made his will, speculate as to what

he might have done in those circumstances, and then supply words to meet

those circumstances.’ Rectification, by David Hodge QC, paragraph 7-33. A

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mistake in a will resulting from the draftsman’s failure to take the testator’s

instructions does not give rise to a claim for rectification.

The statutory remedy

S.20 of the Administration of Justice Act 1982 provides,

‘(1) If a court is satisfied that a will is so expressed that it fails to carry out

the testator’s intentions, in consequence—

(a) of a clerical error; or

(b) of a failure to understand [his] instructions,

it may order that the will shall be rectified so as to carry out [his]

intentions.

(2) An application for an order under this section shall not, except with the

permission of the court, be made after the end of the period of six months

from the date on which representation with respect to the estate of the

deceased is first taken out.

(3) The provisions of this section shall not render the personal

representatives of a deceased person liable for having distributed any

part of the estate of the deceased, after the end of the period of six months

from the date on which representation with respect to the estate of the

deceased is first taken out, on the ground that they ought to have taken

into account the possibility that the court might permit the making of an

application for an order under this section after the end of that period;

but this subsection shall not prejudice any power to recover, by reason of

the making of an order under this section, any part of the estate so

distributed.

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(4) In considering for the purposes of this section when representation with

respect to the estate of a deceased person was first taken out, a grant

limited to settled land or to trust property shall be left out of account, and

a grant limited to real estate or to personal estate shall be left out of

account unless a grant limited to the remainder of the estate has

previously been made or is made at the same time.’

Rectification is only available if it can be established that:

(i) the will fails to carry out the testator’s intentions; and

(ii) what those intentions were.

s.20(1) requires the court to examine three questions:

(i) what were the testator’s intentions with regard to the dispositions

in respect of which rectification is sought;

(ii) whether the will is so expressed that it fails to carry out those

intentions; and

(iii) whether the will is expressed as it is in consequence of either:

(a) a clerical error; or

(b) a failure on the part of someone to whom the testator has

given instructions in connection with his will to understand

those instructions, Re Segelman [1996] (see the extracts

cited by Judge Behrens in Clarke v Brothwood [2006] at

the end of this practice guide.

In the recent case of Re the Hampel Discretionary Trust 1999 [2013]

(which involved rectification of a settlement and not a will by the

exercise of the court’s wider power to grant equitable relief against a

mistake in a voluntary disposition and not a claim under s.20 of the

Administration of Justice Act 1982), commenting on whether the trust

deed as executed failed to represent the true intentions of the parties, the

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Judge stated ‘the existence of a real doubt is enough in a suitable case to

permit the court to rectify a document.’

However please note that:

(i) ‘rectification will not be available where a mistake occurs because

the testator never had any intention relevant to the events which

actually occurred, or where, having applied his mind to them, he

failed to appreciate the legal effect of the words used in his will.’

Rectification, by David Hodge QC, paragraph 7-37;

(ii) ‘the power to rectify [does not] provide any remedy for (i) the

testator’s failure to appreciate the legal effect of the words used in

[his] will; or (ii) uncertainty as to the meaning of his intended

wording; or (iii) a lacunae in the will, because he never had any

intention relevant to the events which actually occurred.’

Theobald on Wills, 17th edition, paragraph 3-035; and

(iii) in Marley v Rawlings & Anor [2012] (Court of Appeal) the

President of the Queen’s Bench Division stated obiter dictum,

‘[Whilst] I do not wish to express a view on whether the powers

under s.20 of the Administration of Justice Act 1982 are as

narrowly circumscribed as has been indicated in the first instance

authorities to which the [trial judge] referred…The scope of s.20

must await a decision where the issue arises. I would simply

observe that there are powerful arguments for the section to be

given a wide and generous scope.’

Clerical error

A clerical error generally means an inadvertent error made in the process

of recording the intended words of the testator in drafting his will,

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Wordingham v Royal Exchange Trust Co Ltd [1992], and Price v

Craig [2006].

‘It seems to me that the words ‘clerical error’ used in section 20(1)(a) of

the Act of 1984 are to be construed as meaning an error made in the

process of recording the intended words of the testator in the drafting or

transcription of [his] will. That meaning is to be contrasted with an error

made in carrying [his] intentions into effect by the drafter’s choice of

words and with a mistaken choice of words because of a failure to

understand the testator’s intentions, a circumstance covered by

subsection (b).’ Wordingham v Royal Exchange Trust Co Ltd [1992].

‘A clerical error occurs where someone, who may be the testator himself,

or his solicitor, or a clerk or typist, introduces words into (or omits words

from) a will without intending to do so, or without applying his mind to

their significance or effect.’ Rectification, by David Hodge QC,

paragraph 7-37.

‘A clerical error occurs when a person does not advert to the

significance and effect of words which he inserts in, or omits from the

will, and thus inadvertently makes an error in the process of recording

the intended wording in either the drafting or transcription of the will.

Rectification may also apply where a draftsman has included a clause

which is inconsistent with the testator’s instructions, where the draftsman

has not appreciated the significance or effect of the same.

Thus rectification is not available if the draftsman of the will understands

the testator’s instructions and deliberately chooses phraseology which he

mistakenly believes gives effect to those instructions.’ Theobald on

Wills, 17th

edition, paragraph 3-034.

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A clerical error does not arise where the draftsman applies his mind to the

provision but there is a misunderstanding of instructions or, having

understood the instructions, through using inappropriate language or a

mistake as to the meaning of the words used; rather it is likely to arise

from either the omission of a relevant provision or the inclusion of a

clause inconsistent with the testator intentions where the draftsman’s

mind has not been applied to the provision and the words omitted or

introduced mistakenly without advertence to their significance or effect,

Re Segelman [1996], see the extracts set out below which include the

following passage,

‘In my view, the jurisdiction conferred by s 20(1), through para (a),

extends to cases where the relevant provision in the will—by reason of

which the will is so expressed that it fails to carry out the testator's

intentions—has been introduced (or, as in the present case, has not been

deleted) in circumstances in which the draftsman has not applied his

mind to its significance or effect. It is to this failure to apply thought that

Latey J and the editor of Mortimer attach the phrase 'per incuriam'.’

In Clarke v Brothwood [2006], where the judge decided that the will

had failed to dispose entirely of the deceased’s residuary estate, which all

parties agree was not his intention, a clerical error was not limited to the

error of the draftsman in transcribing, but extended to a mathematical

error by the deceased in determining the fractions of the estate to be

distributed to certain beneficiaries.

In Pengelly v Pengelly [2007], the judge stated,

‘It seems to me that there is a potential distinction to be drawn between a

situation in which the error alleged occurs as a result of the inadvertent

omission of a word or words, rather than the inadvertent inclusion of a

word or words. It seems to me that, where a word or words has or have

been mistakenly omitted, different considerations may arise, and there

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may well be a greater potential for characterising the error as one of a

clerical nature rather than the section 20(1)(b) situation of a failure to

understand the testator’s intentions…It seems to me that, if the words

have been mistakenly omitted, and the rectification sought is the insertion

of a word or words, it may be possible more readily to bring oneself

within the case of clerical error. The reason for that is that one is more

readily able to find a clerical error where something has been omitted

than where it has been inserted.’

In Joshi & ors v Mahida [2013], the Judge stated, ‘It appears from the case

law that the Courts have not approached the interpretation [of ‘clerical error’]

in the same way as they interpret the ‘slip rule’ now to be found in Part 40, r.12

of the Civil Procedure Rules and s.57 of the Arbitration Act 1996. One might

suppose that clerical error was confined to situations where a zero had been

added to or omitted from a specified sum or a name or a date or a clause

number had been incorrectly stated, i.e. a slip of the pen. The Courts have

however, interpreted the expression in this context more generously. One

reason for this may well be that the jurisdiction to rectify is a very beneficial

one in that it results in the testator’s intentions being honoured and gifts going

to the parties to whom they were intended to go rather than resulting in an

unintended beneficiary receiving a windfall and the intended beneficiary having

to try to redress the situation by suing the solicitor who made the mistake. In

Wordingham v Royal Exchange Trust Company [1992] it was held that

clerical error means an error in the process of recording the intended words of

the testator in the drafting or transcription of the will, with the result that the

omission of a clause which appeared in an earlier will which the testator had

wished to alter in other respects was held to be a clerical error: the missing

clause had not been re-transcribed. In Re Segelman the solicitor omitted to

remove from a previous draft a clause which was inconsistent in effect with his

subsequent instructions as to the beneficiaries. So it seems that if the solicitor in

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drawing up the new will omits an earlier provision that was supposed to remain

or omits to delete in a earlier provision in an earlier draft that has become

inappropriate, those are regarded as clerical errors. It is nevertheless clear that

there is a category of mistake which is not caught by s.20. In Re Segelman

Chadwick J distinguished between three situations, the first two of which

engage s.20 and the third of which does not:

(i) The introduction of words into a will per incuriam without advertence to

their significance and effect (clerical error).

(ii) The introduction of words to which the draftsman has applied his mind

but in relation to which he has failed to understand his instructions.

(iii) The introduction of words to which the draftsman has applied his mind

with a proper understanding of his instructions but which (perhaps

through failure properly to understand the law) did not achieve the

objective which he and the testator intended.’

In Marley v Rawlings [2014] (Supreme Court), Lord Neuberger stated,

‘I accept that the expression ‘clerical error’ can have a narrow meaning, which

would be limited to mistakes involved in copying or writing out a

document…the expression is not one with a precise or well-established, let

alone a technical meaning . The expression can also carry a wider meaning,

namely a mistake arising out of office work of a relatively routine nature, such

as preparing, filing, sending, organising the execution of, a document (save,

possibly, to the extent that the activity involves some special expertise). Those

are activities which are properly to be described as ‘clerical’, and a mistake in

connection with those activities, such as wrongly filing a document or putting

the wrong document in an envelope, can properly be called ‘a clerical

error’…it seems to me that the expression ‘clerical error’ in s.20(1)(a) should

be given a wide, rather than a narrow meaning.’

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Failure to understand instructions

‘A failure to understand the testator’s instructions involves a

misunderstanding or breakdown in communication between the testator

and the person who is drafting or writing out [his] will. It is to be

distinguished from the situation where the draftsman understands his

instructions but uses inappropriate language in seeking to give effect to

them, as where he introduces words into a will to which he has applied

his mind with a proper understanding of his instructions but (perhaps

through a failure properly to understand the law) they do not achieve the

objective which he and the testator intended.’ Rectification, by David

Hodge QC, Paragraph 7-37.

‘[This ground] is limited to cases where the draftsman fails to understand

the instructions given, and thus has a limited scope; it does not cover

circumstances where the testator fails to understand the legal effect of the

words actually used or where the draftsman uses the wrong technique in

drafting the will even though he has understood the intentions of the

testator correctly.’ Theobald on Wills, paragraph 3-034.

The conclusion to be reached by the court about whether the draftsman

had failed to understand the testator’s instructions is ‘to be arrived at on

the balance of probabilities but bearing in mind a strong bias in favour of

the conclusion that a duly executed will evidences the intention of the

testator.’ Goodman v Goodman [2006].

Approach of the court

It is the intention of the testator at the date of the will that falls to be

considered, rather than as at the date of his death.

The standard of proof required is that the court should be satisfied on the

balance of probability.

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However, ‘the probability that a will which a testator had executed in

circumstances of some formality reflects [his] intentions is usually of such

weight that convincing evidence to the contrary is necessary.’ Re

Segelman [1996].

‘[Before] it can be decided (in accordance with s.20 of the

Administration of Justice Act 1982) that the will does not, by reason of a

clerical error or a failure to understand the testator’s instructions, carry

out the testator’s instructions it must first be decided what the document

he executed actually means’. Parkinson v Fawdon [2009].

The construction of a will should depend only on the document before the

court and the wording and context of that. Rainbird & anr v Smith &

ors [2013].

‘[The] correct approach is no different from that of any other document;

it is in accordance with the principles set out in Mannai Investments Co

Ltd v Eagle Star Life Assurance Co Ltd [1997] AC 749 and Investors

Compensation Scheme v The West Bromwich Building Society [1997]

UKHL 28. I have to ascertain the meaning which the will would convey to

a reasonable person having regard to all the background knowledge

which was available at the time the will was made.’ Rainbird & anr v

Smith & ors [2013].

To determine whether the will fails to carry out the testator’s intentions

the court construe his will in the traditional way by ascertaining his

intentions from the wording of the will itself, and on the basis of certain

limited categories of admissible extrinsic evidence, including that

rendered admissible by s.21 Administration of Justice Act 1982 which

provides;

‘Interpretation of wills—general rules as to evidence.

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(1) This section applies to a will—

(a) in so far as any part of it is meaningless;

(b) in so far as the language used in any part of it is ambiguous

on the face of it;

(c) in so far as evidence, other than evidence of the testator’s

intention, shows that the language used in any part of it is

ambiguous in the light of surrounding circumstances.

(2) In so far as this section applies to a will extrinsic evidence,

including evidence of the testator’s intention, may be admitted to

assist in its interpretation.’

‘In construing a will the object of the court is to ascertain the intention of

the testator as expressed in his will when it is read as a whole in the light

of any extrinsic evidence admissible for the purpose of its construction.

The approach to construction is therefore now an intentional one, rather

than a literal one.’ Theobald on Wills, paragraph 15-001.

Civil procedure

Unopposed applications for the rectification of a will may be made to a

district judge or a registrar of the Family Division, and are governed by

r.55 Non-Contentious Probate Rules 1987.

Contested claims should be brought in the Chancery Division and are

governed by CPR 57.12 and paragraphs 9-11 PD.57.

Provided there is no probate action in existence, an unopposed

application may be made to a district judge or registrar of the Family

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Division under r.55 Non-Contentious Probate Rules 1987, which

provides:

‘(1) An application for an order that the will be rectified by virtue of

section 20(1) of the Administration of Justice Act 1982 may be

made to a district judge or registrar, unless a probate action has

been commenced.

(2) The application shall be supported by an affidavit, setting out the

grounds of the application, together with such evidence as can be

adduced as to the testator’s intentions and as to whichever of the

following matters as are in issue:-

(a) in what respects the testator’s intentions were not

understood; or

(b) the nature of any alleged clerical error.

(3) Unless otherwise directed, notice of the application shall be given

to every person having an interest under the will whose interest

might be prejudiced, or such other person who might be

prejudiced, by the rectification applied for and any comments in

writing by any such person shall be exhibited to the affidavit in

support of the application.

(4) If the district judge or registrar is satisfied that, subject to any

direction to the contrary, notice has been given to every person

mentioned in paragraph (3) above, and that the application is

unopposed, he may order that the will be rectified accordingly.’

If opposed it should be commenced in the Chancery Division, using

because of the dispute of fact, the Part 7 procedure, and will be heard by

a High Court Judge.

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‘However, even where a claim for rectification is unopposed it may be

appropriate to proceed in the Chancery Division because, for example,

there is a reasonable prospect that the court may be able to achieve the

testator’s true intention as a matter of construction, and without resort to

rectification; or because independently of any claim for rectification, the

executors require directions about the due administration of the testator’s

estate.’ Rectification, by David Hodge QC, paragraph 10-54.

‘An application for rectification must be made no later than six months

from the date on which a grant of probate…is first taken out; however the

court has a discretion to extend this time limit.’

Theobald on Wills, paragraph 3-035.

The court may proceed on the basis of the guidelines set out in Re

Salmon [1981], and it is submitted that in the context of a claim to rectify

a will a more liberal approach is appropriate, Chittock v Stevens [2000]:

(1) The discretion is unlimited. No restrictions or requirements of any

kind are laid down in the Act, therefore the discretion is plainly one

that is to be exercised judicially, and in accordance with what is

just and proper.

(2) The onus lies on the claimant to establish sufficient grounds for

taking the case out of the general rule, and depriving those who are

protected by it of its benefits. The time limit is a substantive

provision laid down by the Act itself, and is not a mere procedural

time limit imposed by the rules of the court which will be treated

with the indulgence appropriate to procedural rules. The burden on

the applicant is thus no triviality: the applicant must make out a

substantive case for it being just and proper for the court to

exercise its statutory discretion to extend time.

(3) It is material to consider how promptly, and in what circumstances,

the applicant has sought the permission of the court after the time

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limit has expired. The whole of the circumstances must be looked

at, and not least the reasons for the delay, and also the promptitude

with which, by pre-action letter or otherwise, the claimant gave

warning to the defendant of the proposed application.

(4) The existence of negotiations is obviously material.

(5) It is also relevant to consider whether or not the estate has been

distributed before a claim under the Act has been made or notified.

(6) It is relevant to consider whether a refusal to extend time would

leave the claimant without redress against anybody.

‘At the end of the day the court is required to stand back and ask whether

it is proper and just in all the circumstances to extend time?’

Re Segelman [1996]

The following extracts from the judgment of Chadwick J in Re Segelman were

cited by Judge Behrens in Clarke v Brothwood [2006]:

‘The third question in relation to the claim for rectification is whether the

failure of cl 11(a) to carry out the testator's intention is in consequence of a

clerical error or a failure to understand his instructions, or has come about for

some other reason. I am satisfied that the reason why cl 11(a) with its proviso

did not carry out the testator's intention was that Mr White failed to appreciate

on 5 May 1992 that the proviso which he had included in the draft will on his

own initiative had become inapt once he had been instructed that the second

schedule was to take the form which it did. Once he had a list for inclusion as

the second schedule which included the issue of five of the six named

beneficiaries Mr White ought to have deleted the proviso to cl 11(a) from the

draft will. Failure to do so was a mistake. That mistake did not arise from any

failure by Mr White to understand his instructions. Mr White told me that he

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simply forgot that the proviso was there. The question is whether that mistake

can properly be regarded as a clerical error for the purposes of s.20(1).

In this context I find assistance in the passage in Mortimer on Law and

Practice Relating to Probate (1927, 2nd edn) pp 91–92, which is cited with

approval by Latey J in Re Morris (decd) [1970] 1 All ER 1057 at 1066, [1971]

P 62 at 80. The editor of Mortimer suggests a distinction between two types of

case:

'First. Where the mind of the draftsman has really been applied to the particular

clause, then, whether the error has arisen from the fact that he misunderstood

the instructions of the testator, or, having understood the instructions, has used

inappropriate language in seeking to give effect to them, the testator who

executes the Will is—in the absence of fraud—bound by the error so made as if

it were his own, even if the mistakes were not directly brought to his notice; and

the Court will not omit from the probate the words so introduced into the will.

Secondly, where the mind of the draftsman has never really been applied to the

words of the particular clause, and the words are introduced into the Will per

incuriam, without advertence to their significance and effect, by a mere clerical

error on the part of the draftsman or engrosser, the testator is not bound by the

mistake unless the introduction of such words was directly brought to his

notice.'

The distinction between (i) the introduction of words into a will per incuriam

without advertence to their significance and effect (described in that passage as

'a mere clerical error'), (ii) the introduction of words to which the draftsman

has applied his mind but in relation to which he has failed to understand his

instructions and (iii) the introduction of words to which the draftsman has

applied his mind with a proper understanding of his instructions but which

(perhaps through failure properly to understand the law) do not achieve the

objective which he and the testator intended, was preserved when the law

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relating to the rectification of wills was altered by s 20(1) of the 1982 Act. The

distinction had been recognised by the Law Reform Committee in their

nineteenth report ... Interpretation of Wills (Cmnd (1973)); a report which led

to, but which was not wholly carried into effect by, the 1982 Act. The alteration

of the law made by that Act gives power to the court to order rectification—as

distinct from the former power merely to order the omission of words from

probate—and extends that power to cases of failure to understand instructions,

in addition to mistakes in consequence of clerical error; but there is no reason

to think that that which the editor of Mortimer would have recognised as a

clerical error in 1927 was not intended to be picked up by of s 20(1)(a)of the

1982 Act.

In Re Morris (decd) the mistake lay in a codicil by which, inter alia, the

testatrix had revoked cl 7 of her will. It was clear from the evidence that the

testatrix had never intended to revoke the whole of that clause but only to

revoke the pecuniary legacy given by cl 7(iv). The error was that of her solicitor

in giving effect to her instructions. Latey J described the position in these terms

([1970] 1 All ER 1057 at 1067, [1970] P 62 at 81):

'The introduction of the words "Clause 7" instead of "Clause 7(iv)" was per

incuriam. The solicitor's mind was never applied to it, and never adverted to the

significance and effect. It was a mere clerical error on his part, a slip. He knew

what the testatrix's instructions and intentions were, and what he did was

outside the scope of his authority.'

Disclaimer

The information contained in this brochure is only intended as a general guide,

and is provided on the basis of no liability for the information given. If you

want advice about English law upon which legal reliance may be placed you

can instruct me to provide it.

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© Carl Islam 2013