Wednesday, August 14, 2019
759 store Competitive Business Strategy Essay
Introduction Strategic planning is central to management study. It defines the long term direction for the company and all other business functions orbit around their established strategies. This article studies how a company formulates business-level strategies, optimize their competitive positioning and obtain a competitive advantage over their rivals. In order to further illustrate this management issue, this article investigates into the successful competitive positioning of a leading Hong Kong imported food and daily necessity retailer, the 759 Store Ã©Ë ¿Ã¤ ¿ ¡Ã¥ ±â¹. Despite 759 Store has a diversified range of business, this article focuses on its major business function as an imported packaged-snacks retailer. The chain-store has grown exponentially since its establishment in July 2010. By November 2014, it has 210 stores across Hong Kong and has significantly increased its market share in the industry.1 This achievement should be credited to the unique competitive strategy the company has adopted. Michael Porterââ¬â¢s Generic Competitive Strategies analyzes how a company should formulate their business model to give them a specific form of competitive position in the market. The three strategies are low cost strategy, differentiation strategy and focus strategy respectively. Low cost strategy drives company to lower their cost and obtain high efficiency, so they can attract customers with lower prices than their competitors. Differentiation strategy, on the contrary, tries to satisfy customersââ¬â¢ needs in a way that its competitors cannot and it has the competitive advantage by charging premium prices. Focus strategy suggests firms specialize in few segments or target market to attain cost advantage or differentiation advantage in the market.2 759 Storeââ¬â¢s competitive strategy, however, has adopted both the differentiation and the low cost strategy simultaneously to attract and retain customers. On one hand, it has successfully challenged the cost-leaders in the industry by providing more differentiated products. On the other hand, it has minimized its costs so it charges differentiated products at a relatively low price. The two sections below could illustrate how 759 Store achieves this distinctive strategy. Differentiation Strategy In the aspect of differentiation strategy, companies offer customers with the unique products which are extraordinary or high quality. The uniqueness of the products is usually highly valued by the customers. Thus, those products are competitive in the market and are difficult to be replaced. This section is going to examine how 759 Store differentiate their products from others snacks retailers. (1) Never selling the products which customers can find in chain supermarkets 759 Store differentiates itself from other competitors by providing uncommon products in the market. 759 Store cannot race their cost to the bottom when compare with ParknShop and Welcome, the two well established cost leaders. In order to survive under the oligopolistic market, the company differentiates itself by avoid selling the same products that the two major supermarkets are already selling. 759 Store would rather search for new products instead of competing directly with those supermarket chains.3 By selling different brands and types of snacks, customers cannot use the retail price to directly compare the products in 759 Store and supermarkets. Also, when compared, customers would find the products in 759 Store more trendy and unique than the products in the two traditional low cost leaders. (2) Exclusive sources of goods 759 Store differentiates its products by securing the exclusive source of goods by all means. The company first made headlines in 2011 when one of the local biggest distributor, Swire Group, refused to supply Coca-Cola to the store, claiming its retail price was too low which would harm supermarketsââ¬â¢ profit . After the incident, packaged-snacks imported directly from Japan accounted for over 60% of the main sales of 759 Store.4 Therefore, Coils Lam Wai-Chun, the CEO of 759 Store, have handled business connections with Japanese suppliers with great care. He has connected the first Japan snacks supplier in HKTDC Food Expo in 2011 by himself.5 In Japan, local products for domestic sales are not allowed to be sold to foreign companies. Thus, Lam even went to Japan in person searching for suppliers and set up shadow companies in Japan sourcing for any popular and fair-price snacks that areà not yet known to the Hong Kong market.6 That is the reason snacks sold in 759 Store always catch up with the trend in Japan. Thus, 759 Store provides exclusive products which cannot be found in its competitorsââ¬â¢ stores. Furthermore, 759 Store establishes a stable and strong relationship with its suppliers in Japan, which are mostly small and medium enterprises. Some Japanese suppliers have even promised to supply their products exclusively to 759 Store as a gesture to thank the companyââ¬â¢s support during the recovery hardship after the 311 Earthquake in Japan.7 All these business connections helped 759 Store to secure its exclusive sources of goods from Japan. (3) Higher autonomy on goods selection through bypassing local distributors Today, more than 95% of products sold at 759 Store are imported directly bypassing distributors in Hong Kong.8 Therefore, 759 Store enjoys greater autonomy on deciding the variety of products they sell. 759 Store successfully develops a new market segment providing new and popular Japanese snacks to Hong Kong people. The self-reliance nature of 759 Store in terms of product purchasing enables the company to maintain its unique choice of trendy and diversified goods, thus differentiating itself from its competitors. (4) Diversification of goods and fast moving trend 759 Store differentiate itself from others by diversifying its choice of goods and keeping its shopping shelves updated with new goods. Assuming customers from Japan, Korea, Taiwan and Hong Kong all share the same trend and taste, the item selection of 759 Store is based on the seasonal snack sales in Japan. The company only retains its top-500 sales items on its shelves and imports these items again.9 The rest of the products are purchased according to the sales trend of snacks in Japan every week. The sales cycle for each snack product is around 3 months only.10 As a result, customers can always be surprised and refreshed by new snacks while enjoying their preferred snacks. The company has successfully differentiated itself from some traditional differentiators, such as Okashi Landé⺠¶Ã© £Å¸Ã§â° ©Ã¨ ªÅ¾. Both snack stores differentiate themselves from the cost leaders by selling imported snacks from Japan. However, the fast market reaction, diversification and regular replacement of products make 759 Store offers a higher value toà customers than its rivals, as 759 Storeââ¬â¢s products are more responsive to customersââ¬â¢ preferences. Low Cost Strategy Though 759 Store uses a lot of tactics to differentiate itself from its competitors, the company still manages to keep their operation at low cost. Hence, the company does not need to charge their customers a premium price for the extra differentiation strategies. This section would explain how 759 Store do everything possible to lower its cost structure and develop its competitive edge against the cost leaders in the market. (1) Economies of scale through rapid horizontal expansion Horizontal expansion is a growth strategy that expands within the same stage of the production process. 759 Store experienced rapid horizontal expansion which it has opened 210 stores in 4 years. Through rapid horizontal expansion, 759 Store benefits from several economies of scale ââ¬â the reduction of long run per unit cost when the scale of production of a company has expanded. One significant average cost advantage is that the company has increased their bargaining power when purchasing from suppliers. If the scale of the company is small, it cannot enjoy the wholesale price offered by the suppliers.11 After enlarging their scale of operation, 759 stores received a reduction in average input price and transportation cost by more than 10%.12 (2) Cost reduction through backward vertical expansion Backward vertical expansion is another growth strategy 759 Store practices to reduce the cost. By becoming companiesââ¬â¢ own supplier, business can control its inputs and help them to provide more secure transaction.13 Due to the exclusive culture of the Japanese snack production industry, Japanese companies only supply their goods to local companies. To address this problem, 759 Store has to set up their shadowing companies in Japan to take up the functions of distributors. As 759 stores purchase the goods directly from the snack manufacturers without passing through any distributors and wholesalers, they could enjoy a lower import price and maintain a steady input supply by themselves. This in turn reduces the overall cost ofà production by integrating different business stages of business functions. (3) Effective inventory management The storage and management of inventories could be a huge source of expenditures for retailers. Packaged snacks are perishable and thus requires accurate inventory management In order to reduce inventory cost while diversifying its products, for each new product, 759 Store would first import 2400-3000 pieces of them to Hong Kong. The company then experiments the market reaction to the product and decides whether to import the product in bulk or not.14 This practice has greatly reduced the risks of stocking up unpopular goods in the warehouse, therefore reducing the cost for inventory storage. (4) Less costly shop location choice When it comes to choosing shop location, 759 Store does not chase after prime retailing locations with expensive rent. Instead, it usually opts for large, more remote and less visible shop locations in residential neighborhoods. The per-foot-square rent at these locations is generally cheaper and 759 Store can bargain for a lower rent as the shopââ¬â¢s presence can improve pedestrian flow nearby.15 In fact, most 759 Storeââ¬â¢s customers are willing to sacrifice convenience for lower price of products as they usually purchase a lot of goods at once.16 According to the annual report of 2013-14, rent for shops only accounted for about 9.8% of the retail revenue. 759 Store successfully lowers its costs by choosing less popular shop location and turns it to its own advantages. (5) Motivate employee: pay more for employees to work more The 759 Store regards its employees as important assets of the company. It can help reduce the operating cost of the company by successfully motivating its staff to enhance their productivity. It always stresses the provision of a reasonable salary and fringe benefit to its staff. For example, when the existing minimum wage in Hong Kong is $30/hour, 759 Store can pay its staff up to $38/hour. A manager may get an attractive salary up to $30,000 per month. 17 The CEO of 759 Store believes that a reasonable pay will increase working incentive of the staff to provide better service performance andà deliver excellent service to the customers. According to the annual report of 759 Store, one can find that even though the company is renting larger stores, the number of frontline staff is similar as previous year which is approximately 4.1 staff per shop.18 Although the per-labor cost is higher, the overall cost on labor is reduced because the staff is more productive and the company can hire less labor. (6) Inexpensive advertising and communication strategies 759 Stores adopts useful but inexpensive marketing strategies to gain its reputation. Unlike its competitors who promote their brands through traditional advertising channels, like newspaper, radio and television advertisement, 759 Stores uses word of mouth to promote its brand. Since their CEO has a good relationship with the media, he has been repeated interviewed by numerous press and television programs. It has helped 759 Store to gain exposure in the mass media without paying a penny. Also, 759 Store utilizes the technology to communicate with its customers, especially the internet platform like Facebook and blog. These platforms provide channels for 759 Store to communicate and respond to its customer directly. All these measure are cost-minimizing, yet they are very effective. Conclusion In a nutshell, 759 Store has developed its competitive business position by adopting features from both the differentiation strategy and the low-cost strategy. On one hand, 759 Store differentiated itself from traditional cost-leaders by providing exclusive, highly diversified and trendy goods to its customers, through exclusive sources of imported goods and autonomous purchasing practice. It has also avoided direct competition with the cost leaders on identical items. In terms of responsiveness to customersââ¬â¢ taste and catching up with trends, 759 Storeââ¬â¢s performance is even superior to the traditional differentiators in the industry. On the other hand, the company has adopted the strategy to lower its cost structure, therefore it does not has to charge products for premium prices even extra values has been added to its products. It has lowered its per-unit cost by economies of scale through rapid horizontal and backwardà vertical expansion. Other costs are being lowered by having better inventory control, choosing less costly shop location, using unconventional advertising methods and cutting overall labor cost by incentivizing individuals to achieve higher productivity. Some scholars identify this mixture of strategies as the broad differentiation strategy.19 The competitive advantage of companies adopting this strategy is that the company can offer customers quality products at reasonable prices. As 759 Store has demonstrated, it has chosen a level of differentiation that gives the company on the market segment it has targeted. Besides, they have achieved this in a way that has allowed them to lower their cost structure over time. Though it has higher cost than the cost leader, as well as less differentiated products than the differentiator, 759 Store offers more value than its industry rivals, and therefore threatening both the cost leader and the differentiator. In the case of 759 Store, ParknShop, the traditional cost leader in the industry, has even referred to the business model of 759 Store and opened a subsidiary brand in order to compete with 759 Store.20 It is a proof that 759 Store has successfully weakened the competitive position of its rivals by adopting the right strategy. Insights The successful competitive positioning of 759 Store gives insights to future managers on strategic planning, especially regarding how to enter an oligopolistic market. 759 Store has found its unique competitive position to create a ââ¬Ëthird wayâ⬠in the oligopolistic packaged-food retailing market, which was dominated by two traditional cost leaders. By adopting the broad differentiation strategy, 759 Store achieved rapid growth rate of stores and increased its market share steadily in a very short period of time. The successful identification of and expansion into a specific market segment has allowed 759 Store to spread out geographically in Hong Kong quickly. Also, this model cannot be imitated quickly by its competitors. Hence, it is a business model which a lot of companies in the growth stage of their business might want to model upon. We can also find the practices for 759 Store to pursue differentiation and low cost strategies are very innovative. The companyââ¬â¢s unique understanding of market taste and purchasing culture has enabled it to come up with efficient and effective strategies neverà adopted by its competitors. The differentiation by trendiness and the cost minimization through shop location choice are good example of the creative strategies 759 Store has adopted. Moreover, the companyââ¬â¢s culture of giving genuine respect to their employees and suppliers has even given 759 Store special competitive advantages in the market. The business model of adopting broad differentiation strategy, however, is not without risks. In order to achieve this distinctive competitive positioning, 759 Store has developed a number of potential risks. The company has an unhealthy amount of debts due to rapid expansion, which makes the company vulnerable to economic downturns. Besides, when compare with the differentiators and the cost leaders, the profit margin of 759 Store is significantly narrower. Profitability could be sacrificed during the growth stage of the company, but we foresee that the company has to adjust its competitive strategy in order to create a sustainable business model in the future. References 759 Store, ââ¬Å"About Us.â⬠Accessed November 2, 2014. http://www.759store.com/aboutus.php?lang=eng. 759 Store Blog. ââ¬Å"759Ã©Ë ¿Ã¤ ¿ ¡Ã¥ ±â¹- Ã¥ °â¹Ã¨ ³ ¢Ã¦ ±âæⰠ!â⬠Accessed October 24, 2014, http://759store-personnel.blogspot.hk/. CEC International Holdings Limited. ââ¬Å"Annual report 13-14.â⬠Accessed October 24, 2014. http://www.ceccoils.com/doc/art/finance/2014082201/201408220001.pdf. Hill, Charles W. L. and Gareth R. Jones. Strategic Management: An Integrated Approach. Mason, OH: South-Western Cengage Learning. Hong Kong Celebrity Network. ââ¬Å"Lam Wai Chung.â⬠Accessed November 2, 2014. http://www.hongkongprofile.com/2011/10/759.html.
The common law and equity Case Study Example | Topics and Well Written Essays - 3500 words
The common law and equity - Case Study Example Equity's impact remains as strong as ever and traces down its foundation to Norman Conquest. Equity to the layman means fairness and justice, but in the legal context its meaning is much more strictly defined. There are rules of equity which must be obeyed. Like any common law, its development may appear equally inflexible and rigid1. Its rights gave foundation to many modern laws and the remedies are daily used by the legal practitioner of the 1990s. Therefore, it plays a substantial role in (British) English legal system. It is a historical creation with modern usage. It is not a pre-conceived theory rather equity is delineated by a series of historical events.2. In the medieval period the chancellor was the most important person in the country next to the king himself. By varying existing writs or inventing new ones, the chancellor could have some influence on the development of the law. Slapper, G. and D. Kelly (2006) said that the common law system develops whereby a civil dispute had to be brought before the appropriate Royal Court by a writ. A claimant could only sue at common law, if only his complaint came within the scope of an existing writ. In the thirteen century, available writs covered very narrow ground. Even if the claim came within the scope of an existing writ, but only due to some reason, such as the power and influence of the defendant, the opponent could not get justice before a common law court. Latter the petition was used to obtain relief where the common law was inflexible and incapable of providing a remedy. Hanbury & Martin (2005) argued that the common law developed into a comprehensive system, but a litigant could only sue at common law if his complaint came within the scope of an existing writ. However, the systems quickly became rigid because judges, feared a flood of actions as a result of the popularity of the royal justice, which stopped issuing new forms of action. As a result, this attitude proved to be a major obstacle to the development of new rules and principles. By thirteen century, hurt litigants filed a petition to the chancellor, to find a more justified solution to their problem. Chancellor was trying to give relief in tough cases, and the medieval chancellor was peculiarly well fitted for this work. If the petition was successful, the chancellor's conclusion would usually be different from that of common law court. Otherwise the matter would have been litigant at common law court. As a consequence, the growth of these petitions rose. The decisions were made on the basis of fairness and reason and so the notion of 'equity' was founded. The common law tradition grew in to the ELS3 through a long process of rationalization of traditions, customs and local practices, during medieval time. The Anglo-Saxon customs were there before the Norman Conquest, but afterwards were joined with Royal Justice in a consolidation of 'local laws' and a vast body of judicial decisions have been built up which resulted in the forms of the present laws. The common law has developed by the judges during and after this century. Customs have a strong influence, which seemed ceased, in forming the new laws. When equity originally developed, gave a gloss to the common
Tuesday, August 13, 2019
Criminal Identification Procedures in the Twenty-First Century Essay
Criminal Identification Procedures in the Twenty-First Century - Essay Example However, because these advances are still so new it is not always possible to understand their full implication. Do they have unintended consequences? Are they really as useful as they appear? And perhaps more importantly will we become so reliant on this technology that we throw away good old sleuthing techniques and human controls and simply let technology take over? These are all incredibly important questions that we must think carefully about. This essay will examine some of these questions by looking at the pros and cons of specific technological advances. In the criminal justice system there are two opposing modes of looking of how to deal with criminals. The first is the due process model. The gist of this model is that an individual can never be deprived of basic human rights no matter how horrible a crime he or she has committed. Even to put someone in prison is to take away the criminalââ¬â¢s inalienable right to liberty and there must be many appeals and a thoroughly scrutinized process to ensure that everything is done by the book. At its heart the due process model would rather see nine guilty people on the street than one innocent person in prison. The end result of this mode requires many hours of painstaking work by humans checking and rechecking evidence and the court case moving very slowly through the system. The second mode of looking at criminal justice is the Criminal Control Mode. This system puts a high value on locking up guilty people. It focuses on protecting citizens from criminals as quickly as possible. Und er this system more money is spent on policing and deterring and prosecuting criminals as quickly as possible so that the police and prosecutors can move on quickly to the next batch. If an innocent person is caught in the net, that is a tragedy, but what is important is that many bad guys got caught too.
Monday, August 12, 2019
Personal consumption journal Essay Example | Topics and Well Written Essays - 500 words
Personal consumption journal - Essay Example Reason for purchase: Where I work, I am quite limited to what I can buy to eat depending on the day. On days when I am alone in the office, I cannot leave the office premises to buy food. In this case therefore, I am limited to restaurants that deliver fast foods. This has proven to be extremely expensive, therefore, I try no to do it very often. The meal consisted of chow mien, and 2 entrays with soup. I choose this because it was the most appropriate for the money that I had at the moment. I could also eat half of the meal then half later. Reason for purchase: I really needed the face wash. I have always loved the Nivea brand for its high quality products. I was more inclined to purchasing the face wash as it was cheaper by 1$ and I thought I would save this dollar for other reasons especially buying lunch. I would have selected Olay Essentials Refreshing Face Wash which is cheaper and went at 3.9$, but Nivea fulfils my need. Reason for purchase: I purchased this product as it was two dollars cheaper. In as much I do not like the brand, I like the fact that it is cheaper, and it will serve the purpose (Lecture notes, 2014). It is on very rare occasions that I get the chance to save this much. I would have preferred Lââ¬â¢Oreal though for its good quality. Reason for purchase: From the response from my cat, I can easily tell that Fancy Feast Cat Food is delicious. I also purchased this product as it contains a combination of ingredients that have shown good results on my catââ¬â¢s wellbeing. The product is better than Delta Pet which did mot yield good results with my cat. Reason for purchase: I purchased this item as I wanted to add something to my wardrobe. It has been a while since I purchased something new. I was also more motivated in making this purchase as the item was cheaper and would me increase my savings (Lecture notes, 2014). Reason for purchase: My week
Sunday, August 11, 2019
Findings and analysis on branding effect on customer buying behaviour Essay
Findings and analysis on branding effect on customer buying behaviour and loyalty - Essay Example The major findings of the study are given after each table. Table No. 2 exhibits the age-wise distribution of sample respondents. It is clear from the table that all the three group has 20 respondents each. The reason why each group is made up of similar number is that it ensures any personal bias and prejudice. This table exhibits the distribution of respondents on the basis of income level. It reveals that the maximum number of respondents falls in the high income group and low income group has the least number of respondents with 17 respondents. The above table shows whether the respondents have brand loyalty or not. Of the total sample respondents, it is clear that, 55 percent has brand loyalty to certain products. In other words, majority of the respondentsââ¬â¢ buying decisions are influenced by their preference to certain brand which they have already bought. This table exhibits the preference of respondents for brands in their buying decisions. It shows that 65 percent of the total respondents prefer brands as their choice and 20 percent do not support this tendency among buyers. It further states that maximum supporters fall in the age group of 18 to 25. Of the 20 respondents in the group, 11 are of the opinion that brands are important in buying decisions. It is also evident from the table that in the age group of above 25, 10 out of 20 strongly support the argument that buying decisions are influenced by brand preference. This table is meant to show the importance of product quality as a determinant of buying decision among various age groups. The table exhibits that out of 60, 46 sample respondents argue that quality is a prominent determinant of buying decision rather than brand image. The supporters of this argument believe that brand image is the product of endless efforts of the producer to maintain quality and if there is quality, there must be
Saturday, August 10, 2019
Samsungs Business Strategy Report Essay Example | Topics and Well Written Essays - 2750 words
Samsungs Business Strategy Report - Essay Example This is as occasioned by the ever-changing environments in which businesses operate. As each business entity is devising innovative ways of increasing their turnover and market base, the overall competitiveness of the industry is increased, thereby causing the rest of the entities in each specific industry to up the game in order to be at par with the industry (Hoskisson et al 2009, p. 178). Given that there are various industries and business entities all partaking in different business operations, each entity must come up with a strategy that will ensure it thrives in its line of business else it risks being knocked off the competition (Moreton et al 2012, p. 176). In order to achieve and maintain their niche or improve even further, the businesses must consider a variety of aspects including the internal and external factors, in order to ensure their continued success and dominance. Despite this, coming up with the right business strategy is not always an easy task. Various consid erations have to be made to identify the best path forward since a wrong move could send a firm on a downward trend (Sekhar 2009, p. 87). In light of the above, the analysis of Samsung Electronics Company Ltd. in relation to existing and probable business strategy modules would suffice a business strategy report. Samsung Electronics is a transnational electronics corporation based in South Korea. It is the main auxiliary of Samsung Group of companies and has been on a steady rise over the recent couple of years. It operates on the global market platform, with branches in most major cities of the world. Samsung has considerably grown over the last couple of years, thereby increasing its global employee base to upwards of 200000 (Sekhar 2009, p. 187). The company is involved in the manufacture of end user electronic products. On the broad platform, it operates mainly in two expansive business units. These are the end product faction and the module division. The product division is inv olved in the fabrication of user products especially home appliances such as video and audio equipment, kitchen electronics, computers, air conditioners, cameras, printers and communication equipment such as mobile phones and tablet computers. On the other hand, the module division is involved in the business of manufacturing product components such as semiconductors, display products such as LCDââ¬â¢s, TFTââ¬â¢s, AMOLEDââ¬â¢s and storage devices such as SD and microSD cards (Russ 2010, p. 231). Moreover, they partake in electronic consumables such as toners and cartridges for printers apart from the aforementioned products. Given the nature of their businesses, the industry is often tumultuous especially due to the constant innovative technologies that grace the electronics and telecommunications industry (Cant et al 2008, p. 121). Samsung Electronics prides itself with the vision to inspire the world and create the future. Their company profile identifies three strengths in relation to their vision. These are new technology, innovative products and creative solutions, all in a bid to realize the stated vision. Moreover, their main focus is on the industry, the employees and their business partners, and they identify these as the keys to their growth and overall success (Moreton et al 2012, p. 88). Their focus on the industry is aimed at assessing the industry trends to enable them map the best strategy to be the market leader. Meanwhile, the partnership vision is aimed at considering their business associates and generating a correlation targeting success for both partners and the company itself (Cant et al 2008, p. 322). On the other hand, the employee vision has the objective to empower the employees and create a sense in them that lets them diligently partake in their duties
Friday, August 9, 2019
Equity and trusts Degree Case Study Example | Topics and Well Written Essays - 2000 words
Equity and trusts Degree - Case Study Example This is so because, even though equity looks at intent and not form, equity is also bound to take cognizance of the express will of the Parliament. We shall now turn our attention to the provisions of the will made by James: a. 100 000 to my beloved sister - Emily, in absolute confidence that she will use a decent amount to look after my step daughter, Mary: James is entitled to leave as much money as he wills to his sister or on trust for his step daughter. The problem we have in the scenario at hand is that of the three certainties i.e. whether what James stated amounts to a declaration of trust over the 100,000 The second is whether the amount left for Mary is identifiable The issue of objects does not seem problematic as Mary is clearly the intended beneficiary. The last problem that we will deal with is what would happen to the 100,000 if no trust is to be found. To consider whether James has created a valid trust or gave a power of appointment. In Re Weekes' Settlement (1897) a testatrix left property to her husband with a 'power to dispose of all such property by will amongst our children in accordance with the power granted to him as regards the other property which I have under my marriage settlements.' The court decided that the document did not create a trust for the children of the testatrix but a mere power of appointment for the husband to distribute the money if he willed. In the will left by James, an analogy could easily be drawn with the facts in Re Weekes' Settlement (1897). He has left the 100,000 to his sister with a power of appointment that she could use a decent amount of the money for the care of James's step daughter. There are also cases where a relatively clearer intention was found like in Mussorie Bank Ltd v Reynor (1882), here also the question was whether the testator actually wanted to create a trust. However, in light of cases like Lambe v Eames (1871) where the Court of Appeal refused to hold a valid trust because the testator left a estate to his widow stating 'to be at her disposal in any way she may think best, for the benefit of herself and her family' seems to be closest to facts at hand. The only problem in concluding that the money was an absolute gift to Emily is the case of Comiskey v Bowring-Hanbury (1905), where a trust was held on the words 'in full confidence that', in our case, similar words are used. In Comiskey however, the testator's words were construed in such a way also because they were followed by an instruction that if the wife died without devising the property to her nieces then the property will be divided equally amongst them. James uses similar words, 'in absolute confidence' but one may be bound to incline towards earlier authorities as there are no further instructions. This indicates two things, first, that
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