Religion in York is a large Quaker mental hospital, situated in the east of the city outside the city walls. It was founded in 1796 by William Tuke; over the next century his son Henry Tuke, grandson Samuel Tuke and great-grandson Daniel Hack Tuke also devoted themselves to mental health reform, continuing to reform The Retreat and publishing a number of works on the subject. The York-born Quaker chocolate entrepreneurs and social reformers Joseph Rowntree and Benjamin Seebohm Rowntree left an indelible mark on the city, through both their business interests and their philanthropy. They built the village of New Earswick to provide
Secret trusts in English law Act, because it was not created by a will. This view was expressed by Megarry VC in "Re Snowden", where he said "The whole basis of secret trusts... is that they operate outside the will, changing nothing that is written in it, and allowing it to operate according to its tenor, but then fastening a trust on to the property in the hands of the recipient". This suggests that secret trusts are not constructive trusts but rather express trusts. It has been suggested that the "dehors" theory is based on detective drafting of the Wills Act. In particular, whilst the