In finding that an exclusion in a bequest for "investments securities for money or leasehold property" did not include proceeds of life insurance policies, Harman J. first quoted a statement in Jarman on Wills that "'investment' is a vague term and no general rule can be laid down as to its meaning,'" and went on to state (p. 907):
Counsel rested his claim on the word 'investments' saying that anything was an investment which is a mode of laying out money with a view to obtaining a return, and that a man who put out his money to buy himself a policy to be returned a sum, whether at 65 or at his death, was investing money, and that the proceeds will properly be called an investment. I have no doubt that is so, but I think the problem is: What did this testator mean when he excepted 'investments' and 'securities for money?' I think he meant stock exchange investments - stocks in shares - and things which were not stocks or shares but were securities, such as debentures. I do not think he intended to include policy monies in that phrase.