Are IIP Wills Mutual Wills?

Hi everyone

Friday thoughts welcome and gratefully received…

Husband and wife made IIP wills as they had children from previous marriages. Both Wills gifted half property to IIP, residue to surviving spouse, and on second death distributed the estate (including interest in the property) between their combined children.

Husband died – his share of property passes to IIP. Residue to surviving spouse.

Surviving spouse now wishes to remove husband’s child from the Will because they haven’t really stayed in touch since he died. She has remained in the property and benefitted from their agreement re the IIPs.

Is this possible for her to now change the distribution of her share of the property? There is something in my mind, that they have made promised to one another to ensure their joint asset was disposed of a certain way. She has benefited from this promise and now wishes to renege on it.

Thank you for any help or thoughts offered,

Eneia

On the facts as you describe them, the surviving spouse can change her will unless the original wills amounted to mutual wills. The presence of IIP (or IPDI) trusts does not, of itself, prevent revocation or restrict the survivor’s testamentary freedom.

An interest in possession is a trust mechanism, not a contractual one. The husband’s will created an IIP over his share of the property in favour of the surviving spouse. On his death, that trust became fixed and irrevocable as to his share. The surviving spouse is entitled to occupy the property for life, and on her death the husband’s share must pass in accordance with the remainder provisions in his will, including to his child. That position cannot now be altered by the survivor.

However, the IIP does not impose any obligation on the survivor as to the disposition of her own estate. Her own share of the property and her residuary estate remain hers absolutely, and she is free to change her will in relation to those assets unless there is a binding mutual wills arrangement.

Mutual wills arise only where two individuals make wills pursuant to a clear agreement that neither will revoke or alter their will without the consent of the other, and with the intention that the agreement will bind the survivor after the first death. Where one party dies having complied with that agreement, equity enforces it by treating the survivor’s estate as held on a constructive trust when the survivor dies. The key point is that this requires clear evidence of a contractual agreement not to revoke; mirror or reciprocal wills, even carefully coordinated ones, are not enough.

The fact that the survivor has remained in the property and benefited from the IIP does not, in itself, create such an obligation. Benefit alone does not convert coordinated wills into mutual wills. Without clear and compelling evidence of an agreement that the wills were intended to be mutual and irrevocable after the first death, the presumption is that each testator retained testamentary freedom.

Accordingly, the surviving spouse cannot exclude the husband’s child from the husband’s share of the property, because that share is already held on IIP trusts that will take effect on her death. She can, however, change her will so as to exclude the husband’s child from inheriting her own share of the property and her own estate, unless it can be shown that the original wills were mutual in the strict legal sense.

In the absence of a declaration of mutuality, the wills are not “mutual” despite the fact that each is a “mirror” of the other.

Unless there is some, other, contractual arrangement between the parties (which would be unusual but not unprecedented), the wife can dispose of her/the joint estate as she wishes.

Over the years, I have seen many mutual wills, with many containing no statement of mutuality, such statement being within in a separate letter, signed by all the relevant testators (it need not be limited to 2) and held with the wills (or a separate signed copy held with each will). I have always (and continue to do so) considered the statement of mutuality should be set out within the will, and not in a separate document. If in the will, the declaration cannot be “mislaid” or otherwise “lost”, thereby defeating the intention of the deceased testator. This is not a fanciful possibility as I am aware of a number of occasions where that has happened. Often the surviving testator (perhaps the step parent of the deceased testator’s children) has gained possession of the wills shortly after death and, surprise, surprise, there was nothing with the wills when they were handed over to whoever was to administer the estate!

Whilst I appreciate I have strayed from the specific question posed, I believe that anyone drafting mutual wills needs to be conscious of the need to ensure the safe keeping of the evidence of the mutuality following the death of the first testator to die.

Paul Saunders FCIB TEP

Independent Trust Consultant

Providing support and advice to fellow professionals