Which of the Following Is Not a Theory Advanced by the Courts

Which of the following is not a theory advanced by the courts to permit unincorporated associations to hold and enjoy the benefits of property?

A) The association's property and assets are held under a mutual contract by the members, subject to the association's rules.
B) The association's property and assets are held on a charitable purpose trust for the society.
C) The association's property and assets are held on trust for the purposes of the members.
D) The association's property and assets are treated as a gift to the present members beneficially.