DAVID-KRATOS NOTES ON FORMALITIES OF A WILL

Formalities of a will
A will need not take on one particular form . It must only be a true expression of the wishes of a
testator.
The rules regarding formalities in the execution of wills guard against forgery and create
certainty as to validity of testamentary documents.
There are however certain statutory requirements imposed by the wills act that a will must
conform to . These can be found in section 2 of the wills act 1971 that requires a will be in
writing, signed at the end or at the foot and attested to by two witnesses.

1. Writing.
It can be written on anything in any form so far as it is legible. A privileged will made by a
member of the Armed Forces while engaged on active service need not be in writing. Under
section 6(1) (c) of the Wills Act, 1971, such a will may be made orally before two witnesses.
In earlier parlance, the term "will" was employed interchangeably with "testament" and was
usually associated with the grave, weighty and almost sacred final directions given by a dying
man regarding his worldly goods.

A will written on a cigarette packet was admitted to probate in the case of Murray ; and in
Hodson v. Barnes ,a will which had been written on an empty eggshell was held to be valid.

In Re Yena Adumua-Bossman J, held that it is not necessary that a testamentary document

indicates that it is the last Will and testament of the testator. In that case the testator had made a
paper writing disposing of his estate. The document was, nevertheless, admitted to probate on the
ground that it complied with the requirements of the Wills Act, 1837.

In Re Adams is authority for the assumption that the parts in pencil are deliberative and namely
constitutes a draft, whereas the parts in pen are final.

A will written in jeweller's code by a deceased jeweller was held to be valid, and decipherable by
reference to extrinsic evidence as to the business practice of the deceased.

In Re Opoku is authority for the view that a will written in indirect speech is valid.

2. Signature of Testator
A testator must sign his will, or it can be signed for him at his direction. A signature than on
behalf of a testator must be in his presence and at his direction. This is the provision of section 2
of the wills act. It is provided in section 2(4) of the Wills Act, 1971, that where the will is signed
by some other person at the direction of the testator, that other person must sign, in
acknowledgement of that fact, in the presence of the testator and two or more witnesses present
at the same time. A mark or initials are sufficient if intended to represent a signature. A
"signature' may be made even by a rubber stamp. It does not matter that the testator's hand is
guided in making the mark or initials.
In Baksmaty v. Baksmaty, the hand of the testator, who was weak from diabetes, was guided in
making the signature to his will while in the hospital. This was also necessary because the
testator was blind and, after the will had been read over to him, it was necessary to guide his
hand to the position where he had to sign his name on the will. The court, relying on the English

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case of Wilson v. Beddard, held that it was perfectly in order, having regard to the testators
condition to be guided to make that signature .
In the Goods of Chalcraft, The testatrix started to sign her codicil but could not finish on
the account of her failing physical strength. the dying testatrix could only write “E Chal” but it
was admitted as a signature of “E Chalcraft” which was the usual signature, because that was all
that the testatrix intended to write.
In In the Goods of Redding, " the will was admitted to probate although in the signature an
assumed name used.
In the Estate of Cook, the words your loving mother' were accepted as amounting to
signature, because the words were meant to represent the testator's name.
Under section 2(2) of the Wills Act, 1971, the signature of the testator must be physically at the
end of the will.
In the Goods of Hornby, where the testator intentionallv left an oblong space in the middle of
the writing, in which he signed, this was held to be valid because the signature was intended to
authenticate the whole will.
In Palin v. Ponting, the testatrix wrote on the margin of the first page 'See other side for
completion'. On the second page, under the words 'Continuation from the other side, she wrote
certain dispositions. Both pages were admitted to probate although the first page only was
signed. It was explained that the words 'See other side for completion' had the effect of joining in
or interlining the writing on the second page.

Cases, the courts have been more reserved in accepting the placing of signatures.
In the Goods of Anstee the signature and attestation were at the bottom of the first page, probate
was refused to the second page but was granted of the first page only.
In Royle v. Harris, the signature was at the bottom of the first page, the second and third pages
were rejected.
In Re Stalman, where the testatrix signed at the top of the paper because there was no space left
at the bottom, the will was not granted probate.
In In the Goods of Gee, there was an unfinished sentence which was continued on the next
page, thus clearly showing that the second page was not a subsequent addition; but, relying on
Royle v. Harris, only the first page was granted probate because the signature was at the end of
the first page.
In Re Abaka, Adumua-Bossman, J was faced with a situation where the will was on a printed
form, and the first page contained typewritten dispositions. The first page bore the date, the
signature of the testator at the end or foot of the typewritten matter, and the signatures of the two
attesting witnesses just below the testator's signature. There followed three other pages,
numbered 2, 3 and 4, which, as the court found, contained the most important dispositions
of the will. Unfortunately neither of pages 2, 3 or 4 was signed. The court held that probate could
be granted of only the first page, and the 2nd, 3rd and 4ih pages were rejected because they
followed the signature
In the Goods of Mann, the testatrix wrote her will in the presence of the witnesses. She did not
sign the paper but the witnesses did. She then put the paper into an envelope on which she wrote
'The last will and testament of Jane Catherine Cole. The envelope also was not signed by the
testatrix. Probate was granted of both the paper and the envelope, the envelope being regarded as
an attached paper.

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In section 2(2) of the Wills Act. 1971 it is provided that “No signature shall be operative to give
effect to any disposition or direction which is underneath or which follows it or which is inserted
after the signature has been made”.

Josiah Aryee-
The decisions suggest that a testator may make any mark and once it is intended to be his
signature, it will be valid for purposes of the execution of the will. Consequently, mere initials
were held to be a valid signature in In The Goods of Savory and a stamped signature was also
admitted to probate in In The Goods of Jenkins .

In The Estate of Finn an attempted thumb mark which appeared as merely a blot was held to be
a valid signature since it was intended to be as such.

In Re Cook the testatrix had appended the words "your loving mother" to the will. This was
held to be sufficient.

It was stated in Hindmarsh v. Charlton that a signature was either the name of some mark
intended to represent the name. It is necessary that the signature must be complete.

Re Colling where a patient had attempted to execute a will in the presence of two witnesses
while ill in hospital. One of the witnesses was called away while his signature was incomplete.

Although he returned late to sign as witness, the will was refused probate because the partial
signature was invalid as it was not all that the testator had intended.

Section 2(4) of the Wills Act, 1971 provides that another person may sign on behalf of the
testator. Such signature must be made at the testator's direction in the presence of the test or and
two or more witnesses.

It was confirmed in Smith v. Harris that one of the attesting witnesses may also sign on behalf
of the testator. Any person signing on behalf of the testator may also sign in his own name rather
than the testator's.

It is necessary only to sign the last page of the document but all other pages must be attached
either at the time of execution or by incorporation.
By Section 2(2) of the Wills Act, 1971, "no signature shall be operative to, give effect to any
disposition or direction which is underneath or which follows it, or which is inserted after the
signature has been made."

In Re Mann the testatrix signed the envelope containing a testamentary document rather than
the document itself. She had written on the envelope "The last Will and Testament of J.C.
Mann". She had signed the envelope and her signature had been duly witnessed. The will was
held to be valid and was admitted to probate.
This contrasts with the holding in In The Estate of Bean where the deceased failed to sign his
will. Instead he put it in an envelope on which he wrote his name and address. The court found

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that the writing on the envelope was merely for the purpose of identifying the content and held
the will to be invalid for lack of signature.

3. Attestation.
A will must be made or acknowledged in the presence of at least two competent attesting
witnesses by the testator. The acknowledgement is of the signature and not of the will. It does
not matter that the witnesses do not know that it is a will.
It is not necessary that the witnesses know that the document isa will.
In Norga v. Khadijatu the Court of Appeal held that although attesting witnesses must be
capable of attesting a legal document, they need not know that the document is a will. What they
are required to acknowledge is the testator's signature, not his will.

1. the will must be signed prior to the acknowledgement;

2. the signature must be seen at the time of acknowledgement;

it was held in Re Groffman that since the will had not been produced in such a way that the
signature was visible to the second witness, the will had consequently not been
acknowledged to both witnesses. It therefore failed for lack of due execution. Only one of the
proposed witnesses had been present when the testator produced the will and showed the
signature on it.

In Keigwin v. Keigwin it was held that it suffices if the testatrix's signature was clearly on
the will when she produced it to the witnesses and such signature was seen by the witnesses
when they subscribed the will.

In Daintree v. Butcher the testatrix produced a codicil but only told the witnesses that she
had a document requiring two witnesses; the witnesses did not know that the document was
testamentary, the will was held to be valid.

3. the signature may be acknowledged by words or conduct.

In In the Goods of Davies the testator acknowledged his signature by gestures. The court found
this to be sufficient.

Presence- Section 2(3) of the Wills Act, 1971, 'presence requires that witnesses are visible to
each other as well as to the testator. Once it is established that both witnesses were present when
the testator either wrote or acknowledged signature, it must also be shown that the testator was
visible to them. The cases suggest that to be "present", witnesses and testator must be within the
line of vision" of each other.

Yankah v. Administrator-General the court held that if it appears on the face of a will that it
had been properly executed, the presumption by law is that the testator duly acknowledged it)."
Casson v. Dade the testatrix had already signed a will and was sitting in a carriage outsidethe
solicitor's office when the witnesses signed. The court found that although she was outside she
could see the witnesses through the windows. Their attestation was therefore held to be valid.
Wyatt v. Berry presented another type of problem. After the first witness had signed the will
and left, another witness came in and was told by the testator: "It's a bit of ordering of my

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affairs", after which the witness signed. The will was held to be invalid for lack of simultaneous
presence
In Brown v. Skirrow the testatrix took a will to a business precinct to be witnessed by two shop
assistants. The will was held to be invalid as one of the shop assistants had been elsewhere whilst
the other signed.
Couser v.Couser - The testator had made a home-made will but his son had objected. The son
subsequently applied to have probate granted to his step-mother revoked on the basis of
invalidity of the will for improper execution. He argued that the deceased father's signature had
not been acknowledged in the presence of two or more witnesses.
The deceased had signed the will and acknowledged his signature in the presence of both
witnesses after which the first witness signed. After some misunderstanding the second witness
who was on the other side of the room also signed. The court observed
that what was vital was that a witness should be able to see what was going on, and not merely
be looking. The court held that the Testator and the witnesses had all been present in the same
room and had been discussing the will that had been executed and that since all necessary
signatures and acknowledgements were made, the will was valid.

Capacity- It was held in Re Gibson that a blind person is incapable of witnessing a will because
it could not be signed in his "presence" and he could not be a "witness" to an act which requires a
capacity for vision.

Re Piercy -a blind person is attributed with notional vision in regard to the presence of witnesses
who attest his will. Witnesses to a will may well be called upon to be witnesses in court in the
course of probate when they will be open to cross examination by the opposing party. However,
if no witness is available to give evidence as to the due execution of the will,
evidence may be taken from other persons.
Concerning blind persons, the court observed in Re Gibson"I should be inclined to hold that a
'witness' means in regard to things audible, one who has the faculty of hearing,
and in regard to things visible, one who has the faculty of seeing. The signing of a will is a
visible matter. Therefore, I think that a will is not signed in the presence of a blind person."

Re Alhassan's Application
considered the capacity of a minor as witness to a testamentary disposition. The testator had in
his home-made will left the entirety of his properties to his grandson, then four years old.
The grandson had also witnessed the will along with two others It was held that the thumbprint
of the beneficiary infant was of no consequence as he could not have had the necessary intent to
subscribe to the will.

In Re Phibbs a will got lost in the post while being sent to a solicitor's office after the death of
the testator. Two individuals who had posted the will had read it, and were consequently allowed
to give evidence as to execution.

In Re Groffman, " the will was rejected because onlv one witness actually saw the signature at
the time it was acknowledged by the testator, although a few minutes earlier he had told both of
them to witness it; for, the signature must be made or acknowledged to them when they are
present together.

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In Re Colling, the testator, whilst a patient in a hospital, started to append his signature to his
will in the presence of two witnesses. Just after he commenced writing his signature, one of the
attesting witnesses, a nurse, had to leave to attend to another patient and the testator completed
his signature in the presence of only the other witness. The nurse returned soon thereafter and out
her signature to the will after both the testator and the other witness had acknowledged their
signatures to her. The will was held invalid because the signature was not made before both
witnesses present at the same time. The acknowledgement to the nurse did
not save the will because the other witness had by then already signed as a witness; for, the
acknowledgement should be made to both witnesses before they sign.
The witnesses must each sign in the presence of the testator. For. A valid attestation the witness
must write her name.
In Daintree and Butcher v. Fasulo, it was stated of attesting witnesses that: “No doubt, if they
cannot see the signature, the mere calling on them to sign as witnesses Is not enough.”
In the Estate of Gibson,' it was held that since a blind man lacks the faculty of seeing, a blind
person cannot competently witness the signature to a will.
in Pearson v. Pearson, where both witnesses were illiterate, the will was held to be not valid
because of an improper attestation, though the decision did not turn mainly on the illiteracy of
the witnesses.
In Re Yena, all the six witnesses were illiterate and signed only by marks, the will was admitted
to probate by the Ghanaian court.
By section 3(4) of the Wills Act, a disposition to an attesting beneficiary will operate such that
the beneficiary will be purged of the gift.
As such if it is a joint tenancy the other joint tenant can take the whole and if it is a life interest
the remainderman can take immediately. This is known as the doctrine of acceleration.
If the will attested by a beneficiary is subsequently confirmed or republished by a codicil which
he does not attest, the beneficiary becomes entitled to take the gift because it can be said that the
gift arises under the codicil.
Where there were two or more witnesses, so that the beneficiary was only an additional and
surplus witness, it seemed that, on the authority of in the Estate of Bravda, the gift to him was
still invalid under the Wills Act. 1837. This is however bad law in Ghana as now section 3(4)
provides that such a gift is not void.
A privileged will which is not in the handwriting of the testator, it is valid if attested by only one
witness, by virtue of section 6(1)(b) of the Wills Act, 1971. A privileged oral or nuncupative will
under section 6(1)(c) of the Wills Act, 1971, however, must be made before two witnesses.
Under the doctrine known as incorporation by reference, documents which satisfy certain
conditions are regarded as forming a part of the will. even if such documents are unattested. Such
a document is then read as one with the will. For the doctrine of incorporation by reference to
apply the document must be in existence at the date of the will. This is provided for by section 4
of the Wills Act.
In the Goods of Smart, friends subsequently designated in a book were not benefited because
the book was not incorporated, since the testatrix only said in the will that she would designate
the friends (i.e., in future) in a book or memorandum to be found with the will.
Three conditions must be satisfied before there can be an incorporation by reference. Firstly, the
document to be incorporated must be in existence at the time of the execution of the will.
Secondly, the document must be referred to in the will as being in existence at the date of the

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execution of the will. And, thirdly, the document must be identifiable as that referred to in the
will.
In the Goods of Balme, the testator made a bequest to Selwyn College, Cambridge, of his books
as enumerated in his library catalogue, a rather voluminous document. To avoid expense, probate
was granted of the will without requiring the catalogue to be brought to the Probate Registry or a
copy thereof being made. A revoked will, if incorporated by reference in another and properly
executed will, takes effect as if revived.
Alterations and Obliterations.
There are two types of alterations, interlineations and obliterations. An alteration, interlineation
or obliteration may be made before the execution of the will or after its execution.
Where the alteration, interlineation or obliteration was made before execution, the will takes
effect as altered and there would seem to be no difficulty about it.
The onus probandi is upon the person relying upon an alteration in a will to adduce evidence
Under the old law an unattested alteration under the old law was ineffective for all purposes. It
was ineffective as a substitute for the original disposition, and it was also ineffective in revoking
the original disposition.
In Effinch v. Combe the will was read by surrounding the obliteration with a brown paper and
holding the document against a windowpane. This was permitted because it did not involve a
physical interference with the testamentary document.
In the Goods of Itter where slips of paper were pasted over certain dispositions in the will and
new words were written on them, the original dispositions could be read from an infrared
photograph but only from such a photograph. It was held that since it required such, device to
read the original dispositions, such parts as were so covered by Strips of paper were not
'apparent' and could not be admitted to probate
The doctrine of dependent relative revocation." This doctrine is based on the presumption that
the testator intends that the revoked parts of the will should remain valid unless the new
provisions substituted therefor can be effective.

The wills act provides in section 5(1) that:”No alteration made in a will shall have effect unless it
is separately executed in the same manner as Is required for the execution of a will or unless it
has been made valid by the re-execution of the will or by the subsequent execution of a codicil”
If the omission is deliberate, its objective may be to remove the difficulty of determining whether
the effect of a will after an ineffective alteration Is still apparent. No such objective is, however
attained. If the obliteration makes the provision illegible, the effect is a partial revocation by
physical destruction under section 9(1) of the Wills Act, 1971.
In the Estate of Hamer, the testator bequeathed a legacy of "the sum of two hundred and fifty
pounds' but obliterated the words 'two hundred and.' Probate was granted with the blank space,
and it read 'the sum of [blank space] fifty pounds'.

Presumption regarding alterations:

1. There is a general presumption that unattested alterations, interlineations and erasures were
made after the execution of the will and are therefore, ineffective. This presumption may.
However be rebutted by evidence from the will itself or by extrinsic evidence.

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2. A subsequent codicil operates to republish the will section 5(1) of the Wills Act, 1971.

In the Goods of Heath," the testator made various alterations and interlineations, some of which
were attested and some unattested. Among the unattested interlineations was one giving 1,000 to
each of his executors. He also left a legacy of £10.000 to one of the executors.
In a codicil later, the testator recited that he had given £10,000 to the particular executor, by
saying 'As regards the legacy of £11,000 left to.....' It was held that the codicil operated to
republish the will with the alteration.

3. Where a will is written partly in ink and partly in pencil, the parts in pencil are prima face
regarded as deliberative only and not intended to have final effect.

4. Where an alteration Is made to a privileged will, the alteration, without enquiry and unless the
contrary is shown, is presumed to have been made while the testator was still in a position to
make a privileged will.

5. A will which on the face of it appears to have been duly executed is presumed to have been
properly executed until the contrary is proved.

Republication
Republication is a confirmation of an unrevoked will. It can only take two forms.
Re-execution of an existing will; and making of a codicil to an existing will.

In Re Hardyman, for instance, the will left a legacy in trust for the testatrix's cousin's wife. This
will was made in 1898. The cousin's wife of 1898, however, died in January, 1901, and if
the will were not republished the gift would have lapsed. However, in November, 1901, the will
was generally republished by a codicil. It was held that the second wife of the cousin, who was
married in 1903, would take because, although the woman living at the time of the will was dead,
the second wife answered the description after the republication of the will.
if the gift of property in the original will has lapsed or has been revoked or adeemed, it seems
that a mere republication of the will is not sufficient to cover a new asset of a similar description.
Republication: though it may prevent a lapse as in Re Hardyman, cannot revive a lapsed gift
and it does not necessarily revoke intermediate codicils; but a will is deemed to be republished as
altered by codicils and as altered by both attested and unattested alterations, interlineations and
obliteration

Republication may be either express or constructive. In the case of re-execution of an original

will, it constitutes an express republication.

A constructive republication occurs when a testator makes a codicil to his will or some
testamentary instrument from which the inference can be drawn that he wishes it to be a part of
his will. It has been held that ever codicil prima face has the effect of republishing a will to
which it refers unless a contrary intention is shown.

Revival
Revival means the restoration to effect of a will or codicil which has been revoked.

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In the Wills Act, 1971, section 10(1) says: No will or any part of a will which is in anv manner
revoked shall be revived otherwise than by its re-execution or ov a written declaration of an
intention to revive exccuted in the same manner

the elements essential to the revival of a will are (a) a formal act of revival, (b) an intention to
revive the will, and (c) an existing testamentary document which is to be revived.

In the Goods of Davis the testator made a will in favour of a woman whom he later married.
Under the old law the marriage automatically revoked the will. After the marriage the testator
wrote on the envelope in which the will was kept: 'The herein-named [beneficiary] is now my
lawful weddedwife.' These words were signed and attested in conformity with the statutory
provisions for the execution of a testamentary instrument. It was therefore held that it was a
codicil that revived the old will.
revival can only take place of a will which is revoked by an instrument but which has not been
physically destroyed, or which was revoked by operation of law as in the
Case of a marriage under the old law.The mere revocation of a revocatory instrument will not
operate to revive a revoked will. This view is fortified by section 10(1) of the Will
Act. 1971.
The effect of revival is that the will takes effect as if it was executed on the day of the revival.

Privileged wills
The statutory provisions are to be found in section 6 of the Wills Act,1971, formerly in section
11 of the Wills Act. 1837.

Section 6(1) of the Wills Act, 1971, is that:

Notwithstanding any provision of this Act to the contrary, any member of the
Armed Forces of whatever age may, while engaged on active service, make a will in
any of the following forms:

(a) written and unattested, if the material provisions and signature are in the hand.
writing of the testator;
(b) written (whether or not in the handwriting of the testator) and attested by one
witness;
(C) orally before two witnesses.

In section 18 of the Wills Act, 1971, there is the provision that the expression 'active service has
the meaning given to it by section 98 of the Armed Forces Act,1962.

section 1 of the Armed Forces Act, 1962, which originally provided that the Armed Forces of
Ghana are the Army, the Navy and the Air Force. The Armed Forces, under section 2 of the

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Armed Forces Act, 1962, consist of the regular force, the regular reserve, the volunteer force and
the volunteer reserve.
section 1 of the Armed Forces (Amendment) (No. 2) Decree, 1972.- This enactment makes the
officers and men of the Border Guards members of the Armed Forces within the meaning of the
Armed Forces Act, 1962.

A person who is entitled to make a privileged will may exercise that right at any áge.

Cases to note
In The Estate of Bercovitz the testator signed at both the commencement and the end of the
will. The witnesses saw only the signature at the top, the rest of the will being covered by
blotting paper. The will was held to be invalid for lack of due execution.
In Christian v. Intsiful the will of a 90 year old testator with defective eyesight was held valid
on the ground that the testator appeared to understand the contents of the will. Order 66, Rule 19
of the High Court (Civil Procedure) Rules, 2004 (C.I. 47) provides: "Where the testator was
blind or illiterate, the Court shall not grant probate of the will or administration with will
attached unless the Court is first satisfied, by proof Formalities for the Execution of Wills or
what appears on the face of the will, that the will was read over to the deceased before its
execution or that the deceased hid at that time knowledge of its contents.
The above is reinforced by Section 2(6) of the Wills Act, 1971
which provides conditions under which a blind testator may sign a valid will, thus:
2(6) "Where the testator is blind or illiterate, a competent person shall carefully read over and
explain to him the contents of the will before it is executed, and shall declare in writing upon the
will that he had so read over and explained its contents to the testator and that the
testator appeared perfectly to understand it before it was executed.
In In Re Mensah the court provided a rationale behind Section 2(6) of the Wills Act, 1971: "the
intention behind the writing of this new provision in the Act would be that provisions of the
substantive Act should reflect the long-standing practice provided for in the rules which ensures
that the testamentary dispositions of blind and illiterate persons as recorded for them do truly
represent their expressed wishes and nothing else." The degree of visual impairment requiring
protection under the Act is not specified. It is submitted that any visual disability that prevents
the testator from independently reading the will should fall within the ambit of the provision.
Boakyem v. Ansah the court considered the validity of a will executed by an illiterate by way of
a thumbprint duly attested by two witnesses whose signatures appeared below that of the
interpreter's declaration that the contents of the will had been read over to the testator prior to
execution. Adopting a liberal approach to interpretation, Annan, J. held that the purpose of
interpretation in testamentary matters is to give effect to the last wishes of the testator.
Consequently, both the words appearing on the will and the manner of attestation were held to
be capable of satisfying in a substantial manner the requirements of Section 2(6).

Interrorem clauses- a clause disinheriting beneficiaries who question or attempt to vary the
wishes of the testator. They usually take the following form: "Any beneficiary under this will
who disputes any of the gifts hereunder or otherwise involves my estate in litigation shall
absolutely forfeit any gifts and bequests under this will?" These dreaded clauses are actually of
no legal effect.

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