In this article, we recount the recent case of Karim v Steele & Anor, which was determined at trial on 20 August 2025, and consider the key takeaway for will drafters and those concerned about potentially predatory relationships.
Sheila Carter was 84 years old when she executed a will in November 2012 (the 2012 will). The 2012 will gifted Sheila’s jewellery to a long-term friend, Ms West, and then left her entire estate to Ms Karim, aged 54 at the time of trial, who had been Sheila’s live-in carer for many years.
Ms Karim met Sheila in 1998 after responding to an ad placed by Sheila – who suffered from several physical ailments as well as agoraphobia and a pathological fear of being alone - offering a free room in her house in exchange for company.
Ms Karim only stayed one night at Sheila’s house in 1998, which according to Ms Karim’s evidence was very run down. However, when Ms Karim responded to a similar ad in 2006, which happened to also be placed by Sheila, Ms Karim and her three young children moved in with Sheila at her property in London.
Sheila made it clear to Ms Karim that she expected Ms Karim to provide her with 24-hour care in exchange for housing her. Ms Karim agreed to this initial arrangement, and the two became close friends who relied on each other, despite Sheila being at times a difficult character who was prone to changing her opinions frequently. Between 2007 and 2012, Ms Karim loaned the sum of approximately £85,000 to Sheila, to improve Sheila’s property and her quality of life.
In 2011, an agreement was professionally drawn up by Sheila’s solicitors, Romaine Coleman, formalising the arrangements between Sheila and Ms Karim (the 2011 agreement). The 2011 agreement acknowledged the loan of £85,000 from Ms Karim to Sheila, and granted a charge over Sheila’s property securing that sum. Furthermore, the agreement granted Ms Karim the first option to buy the property if sold, as well as the right for Ms Karim and her three children to live in the property rent free for their lifetimes.
The 2011 agreement also acted as a service agreement, detailing the housekeeping and caring duties Ms Karim was to undertake in exchange for payment of £100 per week. On signing the 2011 agreement, Ms Karim also agreed to continue her duties without payment should Sheila run out of money. The agreement was witnessed by a friend and neighbour of Sheila, who gave evidence that she was satisfied Sheila knew what she was doing by signing the agreement.
Sheila told her long-standing friend Ms West on numerous occasions that she wished to leave her house to Ms Karim in recognition of Ms Karim’s care and dedication to her. Sheila followed through on this when she executed the 2012 will, which was professionally prepared by Romaine Coleman and witnessed by a solicitor and a receptionist of the firm.
Around a year later, Sheila met Mr Quinn during a short stay in hospital. Mr Quinn, who was married, was visiting his daughter in hospital at the time. Despite having only met Sheila that day, Sheila reported to Ms Karim that Mr Quinn accused her (Ms Karim) of poisoning Sheila in order to get her house and take her money.
Mr Quinn became an increasingly recurrent presence in Sheila’s life, visiting her during a subsequent hospital visit and then later at her home, where he gave her ‘bed baths’ despite Sheila having carers who attended four times a day to assist with personal hygiene. During this time, Sheila’s fear of being alone worsened to the point where she would call the police any time Ms Karim left the house.
By January 2014, the relationship between Ms Karim and Sheila had broken down due to Mr Quinn’s isolation of Sheila, and Ms Karim moved out of Sheila’s house.
In May 2014, Sheila moved into a care home. In June 2014, Richard Nelson LLP wrote to Romaine Coleman on Sheila's behalf, alleging that they were negligent in advising Sheila to enter into the 2011 agreement with Ms Karim. They also wrote to Ms Karim asserting that she had no entitlement to live in the property although ultimately, no further action was taken. It's clear from the attendance notes of Richard Nelson LLP that it was Mr Quinn who made initial contact with that firm on Sheila’s behalf.
Ms Payne, a friend and former lodger of Sheila’s, gave evidence that around this time Mr Quinn would visit Sheila daily at the care home, and Sheila told Ms Payne that Mr Quinn loved her and was going to marry her. When Ms Payne questioned Mr Quinn about this, he denied making such statements to Sheila as he was ‘a married man’. However, hospital notes record that Mr Quinn was witnessed kissing Sheila during a hospital stay in February 2016. Eventually, Ms Payne was told by the care home that Sheila no longer wished for any visitors, including her long-time friends.
Concerns were raised about Sheila possibly being coerced by Mr Quinn various times throughout Sheila’s GP records, with the manager of the care home commenting that by January 2016 Sheila refused to eat unless Mr Quinn fed her.
In February 2015, Sheila – then aged 86 - executed a will (the 2015 will) appointing Mr Quinn as the sole beneficiary of her estate. The will was prepared by Damsons. First contact with that firm was made by Mr Quinn’s wife in June 2014. However, Damsons did not arrange the execution of the will. The circumstances surrounding its execution remain unclear.
Sheila died in September 2016. A grant of probate was extracted by Dean Steele, a solicitor who was appointed as attorney for Mr Quinn for the purposes of obtaining the grant, as the executors named under the 2015 will had renounced.
In March 2022, Ms Karim brought a claim challenging the validity of the 2015 will and seeking to revoke the grant obtained by Mr Steele. The grounds of challenge articulated by Ms Karim were: a lack of testamentary capacity, want of knowledge and approval, undue influence and fraudulent calumny.
The claim was determined at trial based on written evidence only on 20 August 2025. The judge found that Sheila did have testamentary capacity, notwithstanding her susceptibility to vulnerability due to her physical and mental conditions, and that she did know and approve of the content of her will, as the document and her estate were relatively straightforward.
However, the judge found that the 2015 will was procured through undue influence exerted by Mr Quinn, which was founded on Sheila’s dependence on him, fostered by his isolation of Sheila and exacerbated by her fear of being alone. The judge noted that Mr Quinn did not make any attempt to defend the claim, and did not acknowledge service of the claim form nor file any evidence.
The judge also found that Sheila’s testamentary wishes were impaired by fraud – namely Sheila’s belief that Mr Quinn was romantically interested in her and intended to marry her. The judge stated that if she was wrong about that, the execution of the 2015 will was obtained by fraudulent calumny by Mr Quinn, in making false statements that Ms Karim was poisoning Sheila in order to take her house and money, which he must have known to be untrue.
The 2015 will was therefore held to be invalid, the grant of probate obtained by Mr Steele was revoked. The 2012 will benefitting Sheila’s friend Ms Westand Ms Karim is to be admitted to probate.
As undue influence and fraudulent calumny often happen behind closed doors, they can be difficult to observe and even harder to prove. However, in this case numerous concerns had been raised by the care home and Sheila’s GP. There were also clear shortcomings in the steps taken by the will drafter in breach of what is considered standard practice.
Damsons did not take steps to confirm Sheila’s instructions alone, Mr Quinn was present during the call in which she gave instructions, and Damsons also failed to follow the ‘golden rule’ of obtaining an assessment of mental capacity from a medical professional. Had they done so, the extent of Mr Quinn’s involvement and control may have been exposed.
This case serves as another reminder of the care and diligence which must be exercised by will drafters when dealing with elderly and vulnerable testators.
If you require advice or assistance regarding the validity of a will, contact our disputed wills and trusts team.
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