Re Cook [1965]

This case followed Re
Buckley J considered that the covenant created an
immediate binding trust of promise, but decided against it on the ground that
there cannot be a trust of a promise to transfer future property.
[Many commentators think this ill-founded.
There is no difficulty with trusts of contracts.
Covenant to pay sum to be ascertained in the future is
just as good a chose in action as a covenant to pay a specified sum, and it
creates legal property of value]