Is a voluntary settlement or deed of gift invalid if it is impeached by subsequent creditors?

One of the frequently cited cases is Spirett v. Willows 1865 J.D. (Ch. 70), which did not actually involve a claim by a subsequent creditor.[10] However, on that topic, the Lord Chancellor said: There is some inconsistency in the decided cases on the subject of conveyances in fraud of creditors; but I think the following conclusions are well founded...if a voluntary settlement or deed of gift be impeached by subsequent creditors, whose debts had not been contracted a the date of the settlement, then it is necessary to shew either that the settler made the settlement with express intent, to “delay, hinder, or defraud creditors,” or that after the settlement the settler had not sufficient means, or reasonable expectation, of being able to pay his then existing debts, that is to say, was reduced to a state of insolvency, in which case the law infers that the settlement was made with intent to delay, hinder, or defraud creditors, and is, therefore, fraudulent and void.