Cal. Codes » Probate Code / DIVISION 11. CONSTRUCTION OF WILLS, TRUSTS, AND OTHER INSTRUMENTS / PART 1. RULES FOR INTERPRETATION OF INSTRUMENTS / CHAPTER 2. Ascertaining Meaning of Language Used in the Instrument
California Codes

Cal. Probate Code § 21121 (2026)

Ascertaining Meaning of Language Used in the Instrument

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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, 25 Cal. App. 5th 989 (Cal. Ct. App. 2018).
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Blech v. Blech, 25 Cal. App. 5th 989 (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.”
Blech v. Blech, No. B268326 (Cal. Ct. App. Aug. 6, 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, No. A170303 (Cal. Ct. App. Dec. 4, 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, No. D078893 (Cal. Ct. App. Sept. 6, 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, No. 3:19-cv-00346 (E.D. Ark. Mar. 6, 2024). “CAL. PROB. CODE § 21121. The settling parties are, in effect, proposing a modification of Mrs.”
Godoy v. Linzner, 106 Cal. App. 5th 765 (Cal. Ct. App. 2024). “(Prob. Code, § 21121; Newman, at p. 134; Estate of Rossi (2006) 138 Cal.”
Elijah & Mary Stiny Trusts v. Helen Robins, 167 F.4th 1019 (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, No. C098648 (Cal. Ct. App. Apr. 9, 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, No. E056920 (Cal. Ct. App. Dec. 29, 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, No. A139925 (Cal. Ct. App. Mar. 27, 2015). “” (Prob. Code, § 21121; Newman v. Wells Fargo Bank, N.”
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