Critically analyse the statement of LJ Arden in the context of the formalities required for an enforceable express trust.

…It is not and cannot be literally true that the donor has to do everything which he can, to transfer the property to the donee, as illustrated in T Choithram International SA v Pagarani [2001] 1WLR 1 (PC) where a gift of shares was held to be valid even though vested in the name of only one of the trustees (the donor)…’ ~ LJ Arden in Pennington and another v Waine and others [2002] EWCA Civ 227.

Required:

• Critically analyse the statement of LJ Arden in the context of the formalities required for an enforceable express trust.

Also I would like this written with the oscola referencing styl.