In the Goods of Clark (1973)The testator being about to die, asked the vicar to make a will in his name and sign it. The vicar signed his own name 'signed on behalf of the testator, in his presence and under his direction, by me, CFFurlong, Vicar of Warfield, Berks.' This was deemed valid. The problem with this provision is that Parliament actually allows another person to sign on behalf of the testator provided that it is under the direction and instructions of the testator, but it has not prohibited the beneficiary or witness from signing in the name or help the testator to sign. The case of Barrett v Bem (2012) concerns the fact that the testator was too ill to sign the will and that it was sister Anne who signed it. The Court of Appeal held that the statutory requirement in Section 9(a) that the order to sign involves a more active role on the part of the testator than a mere "acknowledgement" of a prior signature under of section 9(c). According to Justice of the Peace Lewinson, at paragraph 36 in Barrett v Bem (2012): "The court should not find that a will was executed by a third party at the direction of the testator, unless it There is positive and perceptible communication (which may be verbal or non-verbal) by the testator that he wishes the will to be signed on his behalf by the third party. On the facts, there was not enough evidence to conclude that there was such a “direction”. Justice of the Peace Lewinson remarked: “I echo the judge's view that it is clearly not desirable for beneficiaries to be permitted to execute a will in their favor in any capacity; "and that Parliament should consider changing the law to ensure that this cannot happen in the future." In my opinion I completely agree...... middle of paper ......g the will of the testator so long as they signed it, it doesn't matter what they signed - Wilson v. Beddard (1841). Although section 9 does not tell us what amounts to a signature, we have only been told that the signature must be intended by the testator in order to give effect to the will. However, it is thanks to common law that we can know what a signature is. The landmark case of HINDMARSH v CHARLTON by Lord Campbell LC says that there must be the name or a mark intended to represent the name. Unfortunately, this definition was sometimes considered too broad and thus created some contradictory cases such as Re Chalcraft and Re Colling. Wider viewIn Chalcraft EstatesThe testatrix was dying and signed a codicil "E.Chal" but was unable to complete her signature. It was held that the signature was sufficient as she had written