California Codes

Cal. Probate Code § 21121 (2026)

✓ current as of May 2026

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All parts of an instrument are to be construed in relation to each other and so as, if possible, to form a consistent whole. If the meaning of any part of an instrument is ambiguous or doubtful, it may be explained by any reference to or recital of that part in another part of the instrument.

Notes of Decisions

Cited in 10 cases (6 in the last 5 years), 2014–2026 · leading case: Blech v. Blech, 236 Cal. Rptr. 3d 430 (Cal. Ct. App. 5th 2018).

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Blech v. Blech, 236 Cal. Rptr. 3d 430 (Cal. Ct. App. 5th 2018). · cites it 2× “) We also consider in construing the terms of the Trust, Probate Code section 21121, which provides, "All parts of an instrument are to be construed in relation to each other and so as, if possible, to form a consistent whole.”

Blech v. Blech (Cal. Ct. App. 2018). · cites it 2× “) We also consider in construing the terms of the Trust, Probate Code section 21121, which provides, “All parts of an instrument are to be construed in relation to each other and so as, if possible, to form a consistent whole.”

Est. of Barbour CA1/2 (Cal. Ct. App. 2025). · cites it 2× “” (Prob. Code, § 21121.) “The words of an instrument are to receive an interpretation that will give every expression some effect, rather than one that would render any of the expressions inoperative.”

Gaynor v. Jones CA4/1 (Cal. Ct. App. 2022). “” (Prob. Code, § 21121.) “The words of an instrument are to be given their ordinary and grammatical meaning unless the intention to use them in another sense is clear and their intended meaning can be ascertained.”

In Re Elijah & Mary Stiny Trusts (E.D. Ark. 2024). “CAL. PROB. CODE § 21121. The settling parties are, in effect, proposing a modification of Mrs.”

Godoy v. Linzner (Cal. Ct. App. 2024). “(Prob. Code, § 21121; Newman, at p. 134; Estate of Rossi (2006) 138 Cal.”

Elijah & Mary Stiny Trusts v. Helen Robins (8th Cir. 2026). “” Cal. Prob. Code § 21121 . Further, “[t]he words of an instrument are to receive an interpretation that will give every expression some effect, rather than one that will render any of the expressions inoperative.”

Dunbar v. Dunbar CA3 (Cal. Ct. App. 2026). “” (Prob. Code, § 21121.) Where the language of a trust is ambiguous, meaning it is reasonably susceptible to more than one interpretation, extrinsic evidence is admissible to determine the meaning of that language.”

Crowe v. Tweten CA4/2 (Cal. Ct. App. 2014). ““All parts of an instrument are to be construed in relation to each other and so as, if possible, to form a consistent whole. If the meaning of any part of an instrument is ambiguous or doubtful, it may be explained by any reference to or recital of that part in another part of…”

Lucas v. Lilienthal CA1/2 (Cal. Ct. App. 2015). “” (Prob. Code, § 21121; Newman v. Wells Fargo Bank, N.”

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