For an early criticism of the requirements for nuncupative wills set out in the English statute of frauds, see Bentham, supra note 66, at 545-47.
[section][section] 91-5-15, 91-5-17 (2013) (neither limiting value nor barring realty and also allowing unwitnessed nuncupative wills if the total value of bequests is no greater than $100); Mo.
A proposed provision for nuncupative wills appeared in an early draft of the Uniform Probate Code, see Unif.
In a few early instances, oral instructions for the preparation of improperly formalized written wills were given effect as nuncupative wills, see Offutt v.
1916) ("With the growth of learning and progress of letters, the necessity for nuncupative wills ceased to exist.").
534, 550 (1948); see also Langbein, supra note 158, at 22, 52 (averring that nuncupative wills should be ineligible to take effect under a harmless error doctrine because "[f]ailure to give permanence to the terms of your will is not harmless"); cf.
(283.) Cases concerning nuncupative wills continue to appear on occasion, suggesting their continued use in jurisdictions that permit them.
1899) (observing generally the danger of inattentive witnesses to nuncupative wills).
(307.) Chaffin, supra note 281, at 329-30 (also labeling nuncupative wills "primitive").