In Estate Orpen v Estate Atkinson, an important case in the South African law of succession, the testators, the Atkinsons, massed their estates in a joint will. They had one child, a daughter. According to the stipulations of the will, the massed estate would, upon the death of Mr. Atkinson, should he die first, be handed over to the executors of the estate, who would act as trustees; a trust was thus created.