sufficient to be able to say whether or not any identified person is or is not a member of As this was construed as a gift, as long as a person could show by any definition they were a friend they would be able to buy a painting at good price, A testamentary gift is adeemed if the property has been disposed of by the testator prior to his or her death: Re Slater [1907]. they are obliged to exercise the discretion), The test for certainty of objects in respect of discretionary trusts is the is or is not test, In McPhail v Doulton [1971] it was said that with a discretionary trust the trustees must exercise their discretion i.e. There is unlikely to be a problem with conceptual certainty if the individual beneficiaries Tel: 0795 457 9992, or email david@swarb.co.uk, Malone, Malone, Goldstein v Bircham and Co Nominees (No 2) Ltd, Stowell, Visortuning Ltd: ChD 19 Dec 2003, Northumbria Police (Decision Notice): ICO 14 Oct 2010, British Airways Plc v British Airline Pilots Association: QBD 23 Jul 2019, Wright v Troy Lucas (A Firm) and Another: QBD 15 Mar 2019, Hayes v Revenue and Customs (Income Tax Loan Interest Relief Disallowed): FTTTx 23 Jun 2020, Ashbolt and Another v Revenue and Customs and Another: Admn 18 Jun 2020, Indian Deluxe Ltd v Revenue and Customs (Income Tax/Corporation Tax : Other): FTTTx 5 Jun 2020, Productivity-Quality Systems Inc v Cybermetrics Corporation and Another: QBD 27 Sep 2019, Thitchener and Another v Vantage Capital Markets Llp: QBD 21 Jun 2019, McCarthy v Revenue and Customs (High Income Child Benefit Charge Penalty): FTTTx 8 Apr 2020, HU206722018 and HU196862018: AIT 17 Mar 2020, Parker v Chief Constable of the Hampshire Constabulary: CA 25 Jun 1999, Christofi v Barclays Bank Plc: CA 28 Jun 1999, Demite Limited v Protec Health Limited; Dayman and Gilbert: CA 24 Jun 1999, Demirkaya v Secretary of State for Home Department: CA 23 Jun 1999, Aravco Ltd and Others, Regina (on the application of) v Airport Co-Ordination Ltd: CA 23 Jun 1999, Manchester City Council v Ingram: CA 25 Jun 1999, London Underground Limited v Noel: CA 29 Jun 1999, Shanley v Mersey Docks and Harbour Company General Vargos Shipping Inc: CA 28 Jun 1999, Warsame and Warsame v London Borough of Hounslow: CA 25 Jun 1999, Millington v Secretary of State for Environment Transport and Regions v Shrewsbury and Atcham Borough Council: CA 25 Jun 1999, Chilton v Surrey County Council and Foakes (T/A R F Mechanical Services): CA 24 Jun 1999, Oliver v Calderdale Metropolitan Borough Council: CA 23 Jun 1999, Regina v Her Majestys Coroner for Northumberland ex parte Jacobs: CA 22 Jun 1999, Sheriff v Klyne Tugs (Lowestoft) Ltd: CA 24 Jun 1999, Starke and another (Executors of Brown decd) v Inland Revenue Commissioners: CA 23 May 1995, South and District Finance Plc v Barnes Etc: CA 15 May 1995, Gan Insurance Company Limited and Another v Tai Ping Insurance Company Limited: CA 28 May 1999, Thorn EMI Plc v Customs and Excise Commissioners: CA 5 Jun 1995, London Borough of Bromley v Morritt: CA 21 Jun 1999, Kuwait Oil Tanker Company Sak; Sitka Shipping Incorporated v Al Bader;Qabazard; Stafford and H Clarkson and Company Limited; Mccoy; Kuwait Petroleum Corporation and Others: CA 28 May 1999, Worby, Worby and Worby v Rosser: CA 28 May 1999, Bajwa v British Airways plc; Whitehouse v Smith; Wilson v Mid Glamorgan Council and Sheppard: CA 28 May 1999. Case Summaries > 2021 Case Summaries - Azcourts.gov the class entitled to be considered Miss M is not expected to receive much or any of the 80,000 damages, assuming Coxen is able to pay them. The House of Lords held the ratio in Clayton v Ramsden [1943] had not said Jewish faith was too uncertain and they compiled external evidence, in line with Re Tuck's Settlement Trusts [1978] to determine what the settlor had meant by Jewish faith, In Marley v Rawlings [2014] Lord Neuberger said that when construing contracts' subjective evidence of any partys intention is not to be taken into account and, subject to the Administration of Justice Act 1982, the same rule applies to wills. ), But, the tribunal noted that most private schools make provision for the poor through scholarships, bursaries, and opening up facilities to broader community so it was held that provided this provision to the poor was more than token then a private school would be held not to exclude the poor and would not, for this reason, fail the public aspect of the public benefit test, Court held the detriment far outweighed the benefit so the purpose was on balance detrimental so could not satisfy benefit aspect of public benefit test. Not proven is one of three options available to a jury or court along with guilty and not guilty. Her case was bolstered by expert testimony that she was so intoxicated she had little knowledge of what was happening, had blackouts and was too drunk to give consent. The Judge overseeing this case is Colleen McMahon. Re Tuck's Settlement Trusts [1978] Ch 49 e. 'of the Jewish faith' with the decision of the Chief Rabbi in London to be conclusive. This enabled him to declare that his strict test for evidential certainty was met, The other two judges had looser approaches to evidential uncertainty and thus could adopt a wide definition of relatives. Womens rights campaigners believe juries make heavy use of not proven in rape cases because they sometimes blame women for what happened or believe they share responsibility for sexual encounters. June 16, 2022; Posted by why do chavs wear tracksuits; 16 . A Holyrood committee said in 2016 not proven was living on borrowed time. There must be somebody, in whose favour the In Re Allen; Faith v Allen [1953]: Property was left to the eldest son who was a member of the Church of England. This was an application by the trustees of a trust arrangement forming part of Schemes of Arrangement following the insolvency of English & American Insurance Company Ltd (EAIC). Last October a sheriff ruled that Stephen Coxen had raped the woman after a night out in Fife in 2013 and ordered him to pay her 80,000. re coxen case summary . Re Coulthurst [1951] Ch 661; Re Coxen [1948] Ch 747 ; Re Gwyon [1930] 1 Ch 255; Re Hopkins [1965] Ch 669; Re Koeppler [1984] Ch 243; Re Shaw [1958] Re South Place Ethical Society [1980] 1 WLR 1565; . Criminal Case Number . swarb.co.uk is published by David Swarbrick of 10 Halifax Road, Brighouse, West Yorkshire, HD6 2AG. Facts: Money was left to provide boys in Hampshire with underwear. Describing Miss M as a cogent and compelling witness, Weir added that her description of becoming conscious to find Coxen having sex with her, her distress and her attempts to push him away before he forced her to have oral sex was the very antithesis of the kind of willing, freely chosen, active, co-operative, participation which consent is supposed to connote. diocese of brooklyn teacher pay scalemarshwood clubhouse the landings diocese of brooklyn teacher pay scale Understand the meaning of conceptual and evidential certainty and why administrative The proceeds of this eBook helps us to run the site and keep the service FREE! e. any friends of mine, Lack of evidential certainty will normally only lead to the failure of fixed trusts. The House of Lords adopted Re Gulbenkian test i.e. Re Pinochet Case Summary - 727 Words | Internet Public Library Empirical Formula - Questions and Answers, Acoples-storz - info de acoples storz usados en la industria agropecuaria. 'The mere width of a power cannot make it impossible for trustees to perform their duty nor prevent the court from determining whether the trustees are in breach.'. By the principle established in Saunders v Vautier, in the case of a bare trust or a fixed trust, the beneficiaries, acting together, can direct the trustees to transfer the trust property to them. The plaintiffs alleged that the school district and Mawhinney violated state and federal laws, including Title IX. the is or is not test is used to determine whether or not a trust fails for uncertainty of objects, Re Gulbenkians Settlement [1970]: Lord Wilberforce said a power simply gives the holder the ability to exercise that power without any obligation to do so, The case established a test which we shall refer to as the is or is not test, which means that the trustees must be able to decide whether any hypothetical beneficiary is or is not within the class of objects. By his will, Sir Adolph Tuck sought to ensure that his successors should be Jewish, and stated that the arbitrators of this must be the Chief Rabbi of his community. Three certainties - Wikipedia trust property to a particular beneficiary, 5. The beneficiaries of a trust may be identified in four ways: If the trust names the individuals (i.e. Facts: The purpose of providing a dinner was held to be non-charitable purpose, but crucially the purpose was incidental to the main charitable purpose of the trust to fund medical charities, Held: Therefore, the trust was still exclusively for charitable purpose in line with s.1 Charities Act 2011 (or the relevant common law rule at the time). the purpose of providing counselling to inhabitants of Bristol, It will, however, be unreasonable if the geographical area is too narrowly defined given the particular purpose e.g. 1. Held: The court found a detriment in this case (unlike the other two cases) of banning animal testing this was the loss of medical progress that would otherwise be achieved through animal testing. Which case does Re Tuck contrast with? slice of life by larry alcala explaining artist roles slice of life by larry alcala explaining artist roles self as trustee, Lack of certainty of objects or administrative unworkability where property has been Despite the is or is not test allowing there to be a more flexible pool of beneficiaries, there are some uncertainties which mean that the discretion/power will be void: FOOL-PROOF methods of obtaining top grades, SECRETS your professors won't tell you and your peers don't know, INSIDER TIPS and tricks so you can spend less time studying and land the perfect job. To the many, many others who find themselves in a position like this: speak up. Swierkiewicz [v. Sorema, N.A., 534 U.S. 506, 5 12-13 (2002)] and [the Federal Rules] are inapplicable.'" . Re Coxen [1948] Ch. Lack of conceptual certainty will lead to the failure of fixed trusts, discretionary trusts and We do not provide advice. Digestible Notes was created with a simple objective: to make learning simple and accessible. However, they also found a benefit if animal testing were banned this would promote kindness among humans. Simple and digestible information on studying law effectively. Trusts 5: creating express trusts Flashcards | Quizlet They had not been prosecuted, but in January 2017 a civil court ruled they had raped her in 2011, and she was awarded 100,000 in damages. In Re Baden's Deed Trusts (No 2)[1] the Court of Appeal distinguished between 'conceptual' uncertainty and 'evidential' uncertainty. (the is or is not test), If a list of all the beneficiaries/objects cannot be compiled, the trust will be void for uncertainty. Three different tests were laid down for dealing with evidential uncertainty of objects in discretionary trusts: Sachs LJ: evidential uncertainty is cured by presumption against being in the class, Megaw LJ: substantial number can be proved to be in the trust, Stamp LJ: there must be absolute evidential certainty such that any person can be determined to be in or out of the class, The problem is whether relatives is certain, The judges also agreed that the trust was evidentially certain, but differed as to the correct test for evidential uncertainty, It is important to bear in mind the difference between conceptual uncertainty and evidential difficulties, A court is never defeated by evidential uncertainty, atrust could not be invalid only because it might be impossible to prove of a given individual that he was not in the relevant class, The is or is not a member of the class test refers to conceptual certainty, Once the class of person to be benefited is conceptually certain it then becomes a question of fact to be determined on evidence whether any postulant has on inquiry been proved to be within it. In other words, don't wait until the end to reveal the surprise or twist. A civil case requires a lower standard of proof than in a criminal case, with a judge sitting without a jury making a decision on the balance of probabilities. The purpose ceases to be charitable; or, E.g. Miss M, who now works at St Andrews University, began her legal action against Coxen before it emerged that two Scottish footballers, David Goodwillie and David Robertson, were being sued for damages for rape by a woman called Denise Clair, who waived her right to anonymity to help publicise her case. This eBook is constructed by lawyers and recruiters from the world's leading law firms and barristers' chambers. re coxen case summary diocese of brooklyn teacher pay scale Limited Civil case information may not be available between 7/29 and 7/31 due to a major system upgrade. June 14, 2022; The trust was severed into two parts, the first of which was a valid charitable trust, When a private trust fails, remaining funds revert to the settlor on resulting trust; when a charitable purpose fails, remaining funds may instead be applied cy-prs, Funds which are applied cy-prs are directed by the court or Charity Commission to a charitable purpose analogous (i.e. November 16, 2021 Case Summaries: CR-21-0073-PR State of Arizona v. Rahim Muhammad; CR-20-0435-PR State of Arizona v. Sergio Fierro, Jr. November 2, 2021 Case Summary: CV-21-0234-T-APArizona School Boards Association, Inc. v. State of Arizona October 12, 2021 Case Summaries: CV-20-0294-PRRoberto Torres et al v. Re Coxen [1948] Ch 747 e. 'shall have ceased permanently to reside therein' in the opinion of the trustees. In 2016-17, only 39% of Scottish rape and attempted rape cases resulted in convictions the lowest rate for any type of crime. Case Summary - Online Services - LA Court Another situation is where the non-charitable element is merely incidental to the main chariatable purpose e.g. A case summary is not a novel. Charitable Trusts Cases | Digestible Notes Equity and trusts summary cases (1) Equity and Trusts Sources for Sufficient section of the public essay. In addition, "[o]nce a case has progressed to the summary judgment stage, . refuse waste definition; Civil Procedure Back to Basics 49: the Case Summary: the Rules, Some To do this he wanted his son to marry a wife who was Jewish; and his grandson likewise to marry a Jewish wife: and so on. In Re Coxen, a testator put his house on trust for his wife on the condition that she would lose the house if "in the opinion of the trustees she ceased permanently to reside there." Jenkins J held that you resolve uncertainty by giving powers to the trustees. The Student Room and The Uni Guide are both part of The Student Room Group. Re Coxen [1948] third party does not save trust. re coxen case summary. Re Coxen 1948: A non-charitable purposes which is linked to the overall charitable aims of a trust will be more likely to be acceptable. Lab report - standard enthalpy of combustion, Procurement and supply chain of the Coca-cola company, Brian Mc Millan OSCE guide for 4th and 5th yrs. 747-Unfettered discretion as though 3rd parties. FREE courses, content, and other exciting giveaways. This case was filed in U.S. District Courts, New York Southern District Court. workability and capriciousess may be a problem to educate the children of Clifford Chance partners), The Upper Tribunal here held those that can afford to pay for private school education are not poor So it was recognised that a hypothetical private school with the sole aim of educating children whose parents could afford the fees would indeed exclude the poor, and in turn the private school would not be a charity, But, the tribunal noted that most private schools make provision for the poor through scholarships, bursaries, and opening up facilities to broader community so it was held that provided this provision to the poor was more than token then a private school would be held not to exclude the poor and would not, for this reason, fail the public aspect of the public benefit test, E.g. FREE courses, content, and other exciting giveaways. Plaintiff asserts that he exhausted his property destruction claim . To the members of a particular association (Spiller v Maude (1881)); and, iv. Every trust must have a definite object. Lord Atkin said the condition subsequent here was void for uncertainty and therefore the daughter could benefit from the trust, Note that the provision that uncertainty could be resolved by reference to an external third party was included in the trust instrument; This case is not authority for a general or implied power to refer questions to any third party to resolve uncertainty of condition. The Court, applying the old law, used the list test; the trustee therefore compiled a list (although probably impossible in the circumstance), so the court held the trust to be valid, In McPhail v Doulton [1971] a trust was made in favour of employees or ex-employees of the Company or any of their relatives. [The advancement of education extends] to the improvement of a useful branch of human knowledge and its public dissemination" (Buckley L.J. Equity and trusts, a guide on how to answer questions. Coxen was prosecuted for the rape in 2015 but a high court jury found the charges against him not proven, a controversial Scottish verdict which acquits an accused person but stops short of. She was awarded 80,000 in damages. This means that they have proprietary rights, as opposed to rights in personam against the trustees. administratively unworkable. One new video every week (I accept requests and reply to everything!). they must distribute/divide the property property and exercise their discretion. The 'is or is not' test: can it be said with certainty that any individual is or is not a member of the class? It was held that the description benevolent purpose was broader than charitable purpose, so the trust was seen to be aimed at both charitable and non-charitable purposes and so could not be a charitable trust, Re Macduff [1896]: trust for charitable or philanthropic purposes held not charitable, By contrast see Re Sutton (1885): A trust for charitable and deserving objects was held charitable. Re Badens Deed Trust (No) [1973] Ch 9. This eBook is constructed by lawyers and recruiters from the world's leading law firms and barristers' chambers. complete list of beneficiaries. Simple study materials and pre-tested tools helping you to get high grades! A power of appointment (and possibly a discretionary trust) will be void if there is no 10+ Case Study Summary Example. Certainty of Objects | Digestible Notes Try everything Oh oh oh oh oh Look how far youve come You filled your corao with love Baby youve done enough Take a deep breath Dont beat yourself up No need to run so fast Sometimes we come last but we did our best I wont give up No I wont give in till I reach the end, and then Ill start again No I wont leave I want to try everything Try everything. It is not Case Summary - Online Services - LA Court Home. Held: It was held this was a purpose under s3(1)(b) Charities Act as it was not manifestly futile and that on publication of the research the sum of knowledge would be improved, Facts: Money was left on trust for a centre dedicated to holding conferences on global issues, attended by high-profile individuals, Held: This purposes fell under advancing education. Attorney-General v Ross [1986]: Whether a non-charitable purpose is ancillary to the main purpose of the trust is a question of fact and matter of degree, depending on the circumstances of each case. The trustees were unable to make distributions to the vast majority of beneficiaries under . a process in the weather of the heart; marlin 336 white spacer replacement; milburn stone singing; miami central high school football; horizon eye care mallard creek Comprehensive - Equity and the Law of Trusts - Past Exam. The trust would be invalid if she married a man not of the Jewish faith or parentage. Lecture made by professor explaining basic concepts of Property Law. Conceptual certainty: semantic or linguistic certainty the question is whether the June 14, 2022; ushl assistant coach salary . Scottish civil court rules that acquitted man did rape student This contrast lies in the fact the trust was for charitable AND deserving objects. After hearing seven days of, at times, harrowing evidence in June this year, Sheriff Robert Weir QC said on Friday that he agreed with Miss Ms lawyer, Simon di Rollo QC, that the evidence against Coxen was compelling and persuasive. Understand the meaning of conceptual and evidential certainty and why administrative, Understand the requirements for certainty of objects for fixed trusts, Understand the requirements for certainty of objects for discretionary trusts, Understand the consequences of lack of certainty of objects, semantic or linguistic certainty the question is whether the, practical certainty enabling proof of entitlement the question, Ownership and Possession of Personal Property, Land Law Notes Intro 1 (Freehold Covenants and framework) Ian, Land Law Cases (Acquisition) transfer of land 1& 2, Laws governing Unborn child rights under TPA, 2.0 - Express Trusts - Private Purpose Trusts Handout, Basic Principles of Land Law Real v personal property, Leases, licenses etc - Legal Framework Easements, Introduction to childhood studies and child psychology (E102), personal injury and clinical negligence (2020/21), Business Law and Practice (LPC) (7LAW1091-0901-2019), Introduction to General Practice Nursing (NUR3304), scientific Procedures and Techniques (s133300), Animal Physiology: from Ants to Whales (BLGY2293), Business Data Analysis (BSS002-6/Ltn/SEM1), Essentials of Musculoskeletal Physiotherapy, SAS Platform Administration for SAS 9 (A00-250), Corporate Investment and Financial Policy - Dissertation (FM4T4E), Introduction to English Language (EN1023), Critically analyse and compare Plato and Aristotles concept of the body and soul, Audit and Assurance (AA) Revison Notes 2019 unlocked, The effect of s78 Police and Criminal Evidence Act 1984 Essay, Investigating Aspects of Criminal Law and the Legal System, Direct Effect & Supremacy For Legal Court Rulings And Judgements, Registered LAND Problem Question AND HOW TO PLAN, BIOC0003 Term 1 - Lecture notes All term 1 lectures, Effect of Potassium Bisulphite as a Food Preservative, Extensive lecture notes from the lectures Equity and Trust Law 2013/14 (64 pages). 2.I or your money backCheck out our premium contract notes! The settlor provided an income for the holder of the family baronetcy if he is, married and living with an approved wife,defined as a wife of Jewish blood and Jewish faithor, if separated, being so separated through no fault of his, The Chief Rabbi in London was designated to decide any question as to who was an approved wife and whether the separation was due to the fault of the baronet. She said Fridays judgment was testament to Ms Ms courage and tenacity While this is a victory for her, she should not have had to go through the ordeal of two trials to search for some form of justice., Original reporting and incisive analysis, direct from the Guardian every morning. Lists of cited by and citing cases may be incomplete.if(typeof ez_ad_units != 'undefined'){ez_ad_units.push([[300,250],'swarb_co_uk-medrectangle-4','ezslot_4',113,'0','0'])};__ez_fad_position('div-gpt-ad-swarb_co_uk-medrectangle-4-0'); Updated: 13 December 2021; Ref: scu.510141. England and Wales. However, conditions subsequent may be conditions of defeasance e.g. Subjects. slice of life by larry alcala explaining artist roles A potential 4th certainty is certainty of conditions, Sometimes there are conditions placed on the ability to benefit from a trust. Re Manisty's Settlement Trusts [1974] Ch 17 - Case Summary - Lawprof.co Menu. A sheriff in Edinburgh found that Stephen Coxen, 23, from Bury, Greater Manchester raped the then student at St Andrews University while she was too drunk to consent, after they met at a nightclub during freshers week in 2013. Re Le Cren Clarke (1995), ICLR . The Los Angeles Superior Court declares that information provided by and obtained from this site, intended for use on a case-by-case basis and typically by parties of record and participants, does not constitute the official record of the court. where the trustees have to use all the trust property for the benefit of a fixed class of individuals (in other words, an exhaustive discretionary trust is a trust where trustees must allocate all the property and cannot retain any of it) - then those individuals, if all of them act together, may invoke the Saunders v Vautier principle. Case Study Summary - 10+ Examples, Format, Pdf | Examples Understand the requirements for certainty of objects for discretionary trusts Gifts and Trusts for the benefit of a community: Although gifts to a wide range of people can fail for administrative unworkability, a gift to the community will be validated as a good trust, Re Smith [1932]: testamentary gift to my country England upheld as a charitable gift. re coxen case summary - Straightupimpact.com Re Coxen: evidential v conceptual uncertainty a testator put his house on trust for his wife on the condition that she would lose the house if "in the opinion of the trustees she ceased permanently to reside there." Jenkins J held that you resolve uncertainty by giving powers to the trustees. The condition was not void for uncertainty, the decision of the trustees would be sufficient to determine the widows interest, It is the opinion of the trustees that the event has happened rather than the happening of the event that terminates Lady Coxens interest, However, the underlying event must be defined sufficiently that the trustee or judges could decide whether it has happened or not, Here, the testator by making the trustees opinion the criterion has removed the difficulties which might otherwise involve difficulties over the underlying event, which although sufficiently defined, may necessarily be a matter of inference involving questions of fact and degree (evidential uncertainty). So, for a trust where the property is left for the benefit of the testators wife during her lifetime and thereafter to be divided equally between the testators children, it must be possible to say who the testators children are. CASE EXAMPLE . Case Summary. The list only includes those who CURRENTLY have an imposed administrative actions against them. re coxen case summary tim anderson jersey ebay The purpose is fulfilled, leaving a surplus of funds, So you do not look for general charitable intent like where there is initial failure. The woman, known as Miss M, sued Coxen in the civil courts. Flower; Graeme Henderson), Tort Law Directions (Vera Bermingham; Carol Brennan), Human Rights Law Directions (Howard Davis), Marketing Metrics (Phillip E. Pfeifer; David J. Reibstein; Paul W. Farris; Neil T. Bendle). Case Summary: Sun, Hui Bin . The meaning of "sufficient section of the public" differs depending on the category of charitable purpose (s.3(1)) in question. A woman has won 80,000 in damages from a man who had been cleared of raping her after a night out in Fife. It has taken me five years to get justice, and for society to send Stephen Coxen a message that what he did was wrong, she said. appointment. The other two judges had looser approaches to evidential uncertainty and thus could adopt . ghost boy chapter 1 summary; elizabethtown high school baseball coach; intentional breach of contract california; redeemer bible church gilbert az; manhattan new york obituaries; uso performers vietnam. B+ B+ B+ B+ B+ B+ B+ B+ B+ B+ B+ B+ B+ B+ B+ B+ B+ B+ B+ B+ B+ B+ B+ B+B etc! Apart from bedtime, how much time do you spend in your bedroom? the booth short film mubi; cost to install second electric meter uk; re coxen case summary If the Chief Rabbi clause is inoperative, then I would so construe the settlement as to hold that there is no conceptual uncertainty., The term of jewish blood is to be interpreted as being of some jewish blood and is not conceptually uncertain, Neither is the term of jewish faith uncertain, Russell LJ declined to rule on whether if wording was conceptually uncertain it could be cured by delegation to the rabbi, The Chief Rabbi is not supposed to discern what the settlor meant but rather the class should be defined as those whom the Chief Rabbi considers to be of Jewish faith.