Is a plaintiff entitled to a "in trust" award for the services rendered by the victim's wife in a medical malpractice case?

These "in trust" awards which owe their origin to the judgment of Lord Denning in Cunningham v. Harrison, [1973] 3 All E.R. 463 at 469, are difficult to justify in legal theory. Lord Denning did not say that the court's award for the services rendered, in that case by the victim's wife, should be "in trust". He said the victim ought to hold the amount awarded for the nursing services in trust and pay it to her. What is curious, of course, is that when claims are made for special damages - obligations which the victim has undertaken and which he may or may not have discharged - the court does not say the victim holds those amounts "in trust" for his creditors and I am unable to see the difference between the position of the family member who renders services and any other person who has a claim against the victim. But be all that as it may, in a case where there has been no breach of duty to the third person, such a claim as against the wrongdoer is the victim's claim.