A gift by will to named beneficiaries contingent on a collateral event (such as a life tenant dying without children) creates a transmissible interest that passes to the beneficiaries' estates if they predecease the life tenant, provided the contingency is not personal to the beneficiaries. The preference for early vesting and the presumption against intestacy support this construction. Even if such interests are properly characterised as contingent remainders rather than vested interests, they are transmissible where the contingency does not require the donee's survival. The question of whether Luddington v Kime correctly states a rule of the common law was left open.
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