In The Travelers Life and Annuity Company v. Desiderio, 2007 WL 2019795 (Del. Ch., July 3, 2007), read opinion here, the Chancery Court applied the "doctrine of substantial compliance" to waive  the terms of an annuity contract that required a change of beneficiary to be written before it became effective. The doctrine is applied, as here, when strict enforcement of a requirement for a duly processed writing would work an inequity. In this case, a dying man left a detailed message on his insurance agent’s answering machine with clear and specific instructions on the change he wanted, but died a few hours after he left the message–and before he was able to fill out the necessary paperwork required under the terms of the annuity contract.