## Facts

- A trust was established to benefit members of the Methodist Church in West Ham and Leyton.
- The trust aimed to provide recreational facilities and activities for the spiritual, moral, and physical well-being of these members.
- The Inland Revenue Commissioners (IRC) challenged the trust's charitable status, arguing it did not meet the public benefit requirement due to its limitation to a specific group within a particular locality.

## Issues

1. Whether the trust's purposes were charitable under the law.
2. Whether restricting the trust's benefits to a specific group within a community satisfied the public benefit requirement.

## Decision

- The House of Lords held that the trust did not qualify as charitable because it failed to meet the public benefit test.
- The court determined that a charitable trust must benefit the public at large or a sufficient section of the public, not a private or narrowly defined group.
- The group benefiting from the trust (members of the Methodist Church in West Ham and Leyton) was found to be too narrowly defined and lacking the necessary public character.

## Legal Principles

- Charitable trusts must serve a public benefit and not be limited to private or narrowly defined groups.
- The requirement of public benefit derives from statutes such as the Charitable Uses Act 1601 and subsequent case law, including Commissioners for Special Purposes of Income Tax v Pemsel [1891] AC 531.
- The case clarified that restricted classes within charitable objects, unless representing a sufficient section of the public, do not satisfy the public benefit test.
- The judgment reinforced the principle that the benefit must extend beyond specific organizations or groups to qualify as charitable.

## Conclusion

IRC v Baddeley [1955] AC 572 affirmed that trusts limited to narrowly defined classes, such as the members of a particular church within a locality, do not fulfill the public benefit requirement necessary for charitable status; this remains a central doctrine in charity law.
