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Sometimes the alternative expression "neighbourhood" is used, as by Lord Reid in the Hedley Byrne case 1964 A.C. 465 , 483 and Lord Wilberforce in Anns v Merton London Borough Council 1978 A.C. 728 , 751H, with more conscious reference to Lord Atkin's speech in the earlier case.
The popularity of discretionary trusts rose sharply after the decision of the House of Lords in McPhail v Doulton 1971 AC 424 where Lord Wilberforce restated the test for certainty of objects in connection with discretionary trusts.
However, such conceptual objections seem less strong since the decision of the House of Lords in McPhail v Doulton 1971 AC 424 where Lord Wilberforce rode roughshod over objections to widening the class of valid discretionary trusts on the basis that there would be difficulty ascertaining beneficiaries for the court to enforce the trust in favour of.