Acceleration of vested trust interests applies on release of a life interest where no contrary intention appears in the trust deed.

The doctrine of acceleration applies in India to private trusts, including inter vivos settlements, where a prior life interest ends prematurely and the settlor has shown no contrary intention. The Indian Trusts Act, 1882 contains no express rule on the point, but a subsequent vested interest may be accelerated when the prior interest is released. On the trust deed considered, the direction to distribute the property as if the beneficiary had died intestate only identified the beneficiary class and did not create a contrary intention or a resulting trust. The heirs entitled on intestacy therefore took vested interests, and the trustees had to distribute the corpus and unapplied income to that class.

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Issues: Whether the defendant's release of his life interest under the trust deed accelerated the subsequent vested interests in favour of the class of heirs entitled on intestacy, or whether the trust income became subject to a resulting trust.

Analysis: The Indian Trusts Act, 1882 does not contain an express rule on acceleration of subsequent interests on the premature determination of a prior interest. The Court held that the English doctrine of acceleration applies in India to private trusts, including settlements inter vivos, so long as the settlor has not shown a contrary intention and the subsequent interest is vested rather than contingent. On the trust deed in question, the words directing distribution as if the defendant had died intestate did not indicate a contrary intention; they merely identified the class of beneficiaries. The class of heirs on intestacy therefore took a vested interest, and the defendant's release of his life interest brought the prior interest to an end so as to accelerate the enjoyment of the subsequent interests.

Conclusion: The release of the life interest accelerated the vested interests of the defendant's heirs as on intestacy, and the trustees were bound to distribute the corpus and unapplied income to that class.

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