The Rule Against Perpetuities

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would have taken appears to have been erroneous.
The issue took as purchasers, and the gift to them did not include any persons who were born after the interest vested in possession.^ There would seem, therefore, to have been here a good gift either of an equitable fee or an equitable life estate to those issue of H. who were in esse at her death.^ § 398. So in Caldwell v. Willis,^ where there was a bequest to A., and after his death to his "child or children then living, and the descendants of
... such child or children and their heirs forever," the Court, having reached the conclusion that the gift was to all descendants to the remotest generations as a class, naturally held it void as to all; but the construction put on the bequest seems extraordinary, and, entirely apart from any question of remoteness, impossible to carry out.' » See Angell v. Angell, 28 R. I. Hare, 580, § 408, post, where the 592. decision turned upon the construc- ' 41 Md. 488. tion given to the word "family." « See Parker v.

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