The Rule against Perpetuities as originally developed in England and crystalized over two centuries is still alive and thriving in the Commonwealth of Virginia as evidenced by the recent supreme court case of United Virginia Bank v. Union Oil. While a number of states have enacted legislation or judicially adopted ways and means to avoid the harsh results often dictated by the common law rule, it appears that Virginia may be defending a rearguard position which may not be functional in terms of today's commercial world.