• Extrinsic evidence: Healy: 2 nephews with same name and needed extrinsic evidence to clear up discrepancy. Where there is an inaccuracy e.g. in a description, there may also need extrinsic evidence e.g. Re Plunkets Estate: MF was supposed to be living in France but this was no true. However even though the evidence admitted was factually correct, ct held it to be inconclusive. Re Callaghan: ct will decide when the description is inaccurate what the t intended rather than what is factually accurate. Butler v Butler: intention of testator should be clear and seeking out the meaning of the words in a direct fashion. Cts have a reluctance to interfere with wills. Re Julian: this will referred to the ‘Seamen’s Institute, Sir John Rogerson’s Quay’, there was one protestant one there and one catholic one on Eden Quay. Even though there was obviously a mistake, ct refused to allow admittance as on the face of the will, there was no ambiguity and the bequest was made to the catholic institute. Section 90 1965 Act: broadens the basis as to when extrinsic evidence will be admitted and test in Rowe v Law where the majority of SC held that Section 90 1965 Act evidence will have to satisfy a double requirement before it will be admitted: (i) evidence went to intention; and (ii) that there is ambiguity or a contradiction on the face of the will. The dissenting minority said Section 90 1965 Act intended to operate in cases where there would be injustice even if the five formal requirements were complied with. The majority sought however to give effect to the intention as expressed in will. An example is Thornton: bequest to Mayo County Council Ballina area workers; this was held to be void for uncertainty because they couldn’t work out which co-workers were friendly with the testator during his lifetime. Ct could also not conclude that it was co-workers who were friendly during his lifetime were the subject of the bequest, it was held to be void for uncertainty.