Secret trusts arise in circumstances where a testator leaves property to a person by will after having communicated with that person that she or he is to hold the property on trust: McCormick v Grogan (1869) LR 4 HL 82, Lord Hatherley LC at 88, Lord Westbury at 97. The trust is fully secret where there is no indication in the terms of the will that the person is to hold as trustee. For example, in Voges v Monaghan (1954) 94 CLR 231 the testator requested a beneficiary of his estate to maintain his widow even though the testator’s will evinced nothing to this effect.