The Court held that neither a brief notation on an envelope nor a detailed personal letter found near the deceased constituted an informal will under s 32(2)(a) of the Wills Act 1970 (WA). On the facts, the generality of the language, the absence of any indication the documents were intended to operate as a will, and the deceased's distressed state meant the Court was not satisfied on the balance of probabilities that the deceased intended either document to be her will. A grant of administration was accordingly made to the deceased's brother on an intestacy basis under the Administration Act 1903 (WA).
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