The applicant sought a Certificate of Appointment of Estate Trustee with a Will based on a handwritten document by the deceased that purported to incorporate a typewritten draft will by reference.
The deceased had been unable to execute the formal will due to COVID-19 hospital restrictions.
The court dismissed the application, finding that the handwritten document did not independently make any disposition of property and therefore was not a valid holograph will.
Furthermore, the court held that a holograph will cannot incorporate a typewritten document by reference, as a holograph will must be wholly in the testator's handwriting.
