Thompson v. Royal 163 Va. 492, 175 S.E. 748 (1934) Kroll signed a valid, enforceable will, later adding a codicil. A few weeks later, she returned to her attorney and asked for the will to be destroyed. The attorney did not physically destroy the will, figuring that if Kroll wanted to make a new will later, this document could be used as a draft. Instead, he wrote, "this will is null and void" on the back and had Kroll sign. A few months later, Kroll died, leaving no new will. Those who were mentioned in the will but who wouldn't inherit under intestate succession, submitted the will for probate. The Probate Court accepted the will. Those who stood to gain from intestate succession, appealed, claiming that the will had been revoked. The Virginia Supreme Court affirmed and found the will to be valid. The Virginia Supreme Court found that under Virginia State law, there are several ways to revoke a will, including: Writing a subsequent will. Physically destroying on defacing the will. The writings on the back of the will did not deface or obliterate any part of it, and Kroll never got around to making a new will, so this one is still valid, regardless of what it says on the back. The general rule was that you cannot revoke a will by written memorandum. You must physically destroy it, or write a new will that supersedes it. Under the Uniform Probate Code § 2-507, you can now revoke a will by cancellation, even if said mark or cancellation doesn't deface or obliterate the text of the will.