current speech, and is restricted to institutions where the poor or
needy are relieved. No such distinctive meaning can be attributed
to "charitable purposes"; indeed, the judgment recognizes that
expression " charitable purposes" has the broad Elizabethan
aning, and that the Courts must apply that meaning unless the
text forbid it. A similar distinction between " institution " and
"purposes " seems, indeed, to be suggested by sec. 11 (1) of the
same Act. For sub-sec. 1 (d) exempts "the income of a religious,
scientific, charitable, or public educational institution," whereas
'sub-see. 1 (f) exempts "the income of a fund established by any
'will or instrument of trust for public charitable purposes." There
m surely be no doubt that the latter exemption applies to
ritable purposes in the broad sense of the Statute of Elizabeth.
e other case is that of Inland Revenue Commissioners v. Scott
), which is more complex. As corporations and such bodies do
not die, and are not liable to probate or succession duties, an Act
of 1885 imposed a duty upon the annual value of property vested in
such bodies, but made certain exemptions - sec. 11, sub-sec. 2, of
property legally appropriated for the benefit of the public at large, &c.,
or in any manner expressly prescribed by Act of Parliament ; sub-sec.
}, of property legally appropriated "for any charitable purpose, or for
promotion of education, literature, science, or the fine arts."
Land called the " Intack," near York, was held in trust for the
freemen of a ward of the city, and was under the control of pasture-
'masters, who applied the net profit to the benefit of poor freemen ;
but not under any Act. It was held by the Court of Appeal that in
such a context the words " charitable purpose " could not mean a
purpose charitable in the Elizabethan sense. The reason was that the
whole of sub-sec, 2 as to property for the benefit of the " public at
large * would be wholly unnecessary if " charitable " had the Eliza-
bethan sense in sub-sec. 3; and the words " or for the promotion
of education, literature, science, or the fine arts" would also be
unnecessary. A trust "for the promotion of education" in that