“…a devise to Trustees usually is for the benefit of the cestui que trust or beneficiary, and as words of limitation after the devise to the Trustees may contain various trusts, the Trustees must have the fee simple in order to deal with the trust in any way the Trust directs; otherwise it would be difficult to administer a Trust if Trustees with only life interest died before the beneficiaries. If there are no words of limitation after a Trust or in a conveyance, it operates to pass only a life interest.”

Per JOHN IDOWU CONRAD TAYLOR, JSC in SHONEKAN V. SMITH (1964) LCER-307(SC) (Pp 10 – 11, Paras E – A)