How have the courts interpreted the meaning of a settlement in a personal injury case?

In Freeman v. Pope (1870), L.R. 5 Ch. 538, at p. 541, Hatherley, L.C., said:—"… if a person owing debts makes a settlement which subtracts from the property which is the proper fund for the payment of those debts, an amount without which the debts cannot be paid, then, since it is the necessary consequence of the settlement (supposing it effectual) that some creditors must remain unpaid, it would be the duty of the Judge to direct the jury that they must infer the intent of the settlor to have been to defeat or delay his creditors, and that the case is within the statute."