Goodman v Gallant [1986] Fam 106

Facts

• Mrs. Goodman and Mr. Gallant purchased a house, with Mrs. Goodman contributing one-third of the price and Mr. Gallant two-thirds.
• The parties signed a trust statement confirming they held the property as joint tenants in equity.
• Mrs. Goodman later sought a larger share of the property, alleging a subsequent agreement entitled her to more.
• The matter was brought before the Court of Appeal, with Mrs. Goodman challenging the binding effect of the express trust statement.

Issues

1. Whether a party can claim a greater beneficial interest in jointly owned property than specified in an express trust statement, based on contributions or alleged subsequent agreements.
2. Whether express trust statements about beneficial ownership are final and binding, or can be altered by informal arrangements or changing circumstances.
3. In what circumstances, if any, an express trust statement specifying beneficial shares may be challenged.

Decision

• The Court of Appeal held that the express trust statement was binding and determined the parties' beneficial interests.
• Mrs. Goodman’s claim to a larger share based on an alleged subsequent agreement was rejected.
• The court established that, once an express statement as to beneficial shares exists, it is determinative, regardless of initial contributions or other informal understandings.
• The only exceptions to the rule are cases involving fraud, coercion, or mistake, which must be proved by the party seeking to challenge the statement.

Legal Principles

• An express trust statement specifying beneficial interests in jointly owned property is conclusive and binding between the parties.
• Unequal financial contributions, subsequent agreements, or changes in circumstances do not affect the binding nature of a clear express statement.
• Disputes about beneficial interests are resolved by reference to the document itself; only strong evidence of fraud, coercion, or mistake can alter its legal effect.
• Express statements take precedence over resulting and constructive trust doctrines, which would otherwise infer division from payments or intentions.

Conclusion

Goodman v Gallant confirms that an express trust statement determines beneficial ownership in jointly held property, with challenges possible only on grounds of fraud, coercion, or mistake. The decision provides clarity and finality for parties entering into joint property arrangements by emphasizing the importance and binding effect of express declarations.