Charitable trusts are created for social purposes, rather than for the benefit of identifiable persons. The beneficiary principle (Morice v Bishop of Durham (1804) 9 Ves 399; 32 ER 656) requires express trusts to have identifiable persons as their object, primarily so that there is someone with sufficient standing to enforce the trust in court. Charitable trusts are an exception to this principle, and thus do not require certainty of object. In order to be valid, however, they must be for the benefit of the public. Additionally, the social purpose they perform must be legally recognised as being charitable. The law concerning charitable purposes is over 500 years old, and sourced in general terms from the Preamble to the Elizabethan Statute of Charitable Uses 1601. Since Pemsel’s case in 1891, charitable purposes are grouped into four headings: trusts for the relief of poverty, the advancement of education, the advancement of religion, and for other purposes beneficial to the community. For purposes of Commonwealth legislation, whether a purpose is charitable is now determined according to s 12 of the Charities Act 2013. Charitable trusts can continue in perpetuity.