Supreme Court of Turks and Caicos Islands

The Supreme Court has original jurisdiction in civil and criminal matters; appellate jurisdiction over appeals from the Magistrate’s Court and other statutory bodies such as the National Insurance Board and the Liquor Licensing Board; and supervisory jurisdiction over lower adjudicatory bodies and the actions of government.

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24 judgments
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24 judgments
Citation
Judgment date
November 2017
Civil Procedure
27 November 2017
Whether an association's exclusion from an exclusive terminal rank constituted unlawful interference or negligent misrepresentation.
Tort—unlawful means causing loss; procuring breach of contract; association’s contractual exclusivity with third party; duty of care of an association to members; negligent misrepresentation by non‑disclosure (positive assertion required).
17 November 2017
October 2017
Lease promises to permit private commercial development within a national park were invalid; the Crown cannot fetter future statutory discretion.
National parks – scope of permissible development under National Parks Ordinance; Crown contracts – inability to fetter future executive/statutory discretion; invalidity of contractual promises to grant statutorily regulated development permission; requirement of statutory process to alter park boundaries; remedies where contractual promise procures an unlawful development.
18 October 2017
September 2017
Commission entitled to hold a Code of Conduct inquiry despite prior referral and delay absent evidence of prejudice.
Integrity Commission — distinction between investigation and statutory inquiry — no functus officio from referring matter to prosecutors — no statutory bar to subsequent Code inquiry after criminal proceedings unless statutory time-bar or undertaking exists — delay alone insufficient to quash inquiry absent prejudice — separation of investigative and adjudicative functions.
13 September 2017
Administrative Review
13 September 2017
Court granted summary and default judgment: guarantor’s defences were incredible; counterclaim struck out for lack of particulars.
Banking law – Guarantees and security; Summary judgment – defendant must show fair/reasonable probability of a credible defence; Guarantee covering present and future liabilities; Misrepresentation by silence – burden and credibility; Pleading requirements – particulars required for allegations of fraud/negligent misrepresentation; Default judgment for failure to file defence.
4 September 2017
July 2017
Applicant must indemnify innocent third parties for compliance costs, but adversarial challenges attract reduced cost recovery.
Norwich Pharmacal/disclosure orders; preservation orders; costs of innocent third parties; application of Totalise principles to preservation orders; limits where third party takes adversarial stance; trustees' indemnity for unsuccessful jurisdictional challenges.
26 July 2017
The Declaration created no valid TCI trust: no legal transfer occurred and no beneficiaries were identified.
Trusts — validity and constitution — requirement of legal transfer of trust property to trustee; unincorporated entity cannot hold legal title — beneficiary principle — private trust void if no ascertainable human beneficiaries — estoppel not to preclude preliminary judicial determination of trust validity.
17 July 2017
Ex parte wardship granted where respondent’s secret removal of the child abroad constituted abduction, justifying return proceedings.
Wardship — Child removal from jurisdiction — Surreptitious obtaining of passport and secret departure — Conduct comparable to parental abduction — Ex parte relief justified to protect child’s welfare — Return proceedings permissible.
14 July 2017
June 2017
30 June 2017
A winding-up petition was stayed because a reasonable buyout offer existed and the petitioner unreasonably refused the alternative remedy.
Companies law – just and equitable winding up – minority shareholder excluded from management – availability of alternative remedy by buyout – abuse of process. Company valuations – independent expert valuation as basis for reasonable buyout offer. Procedural remedy – stay of petition to permit buyout by agreed independent expert; dismissal upon completion.
15 June 2017
Costs
13 June 2017
May 2017
The successful applicant recovered standard costs; indemnity costs denied as the respondent's honest mistaken defence did not meet the high threshold.
Costs — successful plaintiff entitled to costs — indemnity costs require culpability or utterly unreasonable conduct — honest but mistaken defence insufficient; statutory interpretation — meaning of "hotel licence" in Regulations; assessment of public-interest/test-case character for costs.
31 May 2017
Court awards 2% on general damages and local short-term deposit rates on special damages, rejecting the statutory post-judgment rate.
Damages — Pre-judgment interest — statutory post-judgment rate inappropriate — general damages: 2% from date of writ — special damages: interest based on local short-term deposit rates (full rate where loss arose shortly after accident) — use local bank rates rather than UK Special Investment Account rates.
11 May 2017
Leave granted to serve foreign defendants where serious issues exist and Turks and Caicos is the appropriate forum.
Service out of jurisdiction — application under Order 11/0.11 — requirements: serious issue to be tried; good arguable case that claim falls within jurisdictional gateways (r 1(1)(c), r 1(1)(v)); forum conveniens — Turks and Caicos clearly appropriate forum — claims of breach of fiduciary duty, knowing receipt and dishonest assistance relating to transfers of TCI company assets.
3 May 2017
Application to restrain mortgagee’s sale dismissed for lack of exceptional circumstances and no undertaking in damages.
Civil procedure – interlocutory injunction – application to restrain mortgagee’s power of sale – American Cyanamid principles applied. Mortgages – undertaking in damages – McLeod v Jones rule requiring payment into court of amount claimed by mortgagee before relief. Mortgages – sale at undervalue – mere assertion insufficient; mortgagee need only obtain best price reasonably obtainable at date of sale. Remedies – damages ordinarily adequate where undervalue alleged; injunction only in exceptional circumstances. Property law – restriction on sale to Belongers does not preclude exercise of power of sale under charge.
3 May 2017
April 2017
A defendant successful after rejected settlement offers is not entitled to indemnity costs absent moral turpitude or highly unreasonable conduct.
Costs  indemnity v standard; Order 62 r 3(4); high threshold for indemnity costs (moral turpitude or highly unreasonable conduct); relevance of CPR Pt 36 and payments into court; settlement offers and timing.
24 April 2017
Petition was not frivolous; challenge to Voter's List arguable, but unproven allegation of improper motive warranted a 30% costs award to other respondents.
• Election law – costs – petitioner not frivolous where challenge to Voter's List under s.80 of Elections Ordinance was arguable. • Election law – decision by lot – ground challenging lot had no merit. • Public officers – imputations of improper motive unsupported by evidence attract adverse costs consequences. • Costs – proportionality and public interest in election challenges; partial costs order (30%) against petitioner for unsubstantiated imputation.
24 April 2017
Civil Procedure
20 April 2017
Court found defendant liable to repay $11,000; awarded post-judgment interest and proposed pre-judgment interest pending submissions.
Civil law – Money had and received/loan – whether payment was $11,000 for purchase or $6,000 loan; credibility of witnesses; fabricated receipt effect; discretionary award of pre-judgment interest under s.19(2) CPO; post-judgment interest under s.20(1) CPO.
13 April 2017
Proprietary claim against local entities is not referable to arbitration; stay application refused.
Arbitration clause – scope and applicability; proprietary claim vs. contractual remedies; stay of proceedings; waiver by steps in proceedings; jurisdiction clause permitting enforcement where assets located.
5 April 2017
March 2017
Settlement barred claims arising from the 4 March incident; proven assaults did not attract vicarious or employer liability, claim dismissed.
Employment torts – alleged workplace assaults and bullying on board yacht – settlement releasing claims from specified incident – admissibility and effect of compromise; vicarious liability for intentional wrongs – close connection test (Lister/Bazley/Catholic Child Welfare); employer’s duty to provide safe system of work and protection from bullying (Wilsons & Clyde, Waters, Baker v Quantum) – causation, reasonableness of employer response; credibility and contemporaneous evidence.
30 March 2017
The applicant bank entitled to indemnity for sums paid under retention bonds; implied undertaking and summary judgment granted.
Banking law – Retention bonds – payment by bank as surety – implied indemnity by principal. Civil procedure – Summary judgment – establishment of prima facie case and leave to defend. Insolvency/charges – Debenture – continuing security not discharged by letter to Receiver. Set-off and account – speculative counterclaims and unrelated litigation do not defeat summary judgment.
28 March 2017
Applicant failed to prove lack of other assets; court refused variation of restraint order for living, strata and child expenses.
Proceeds of Crime – Variation of restraint order – Applicant’s burden to prove no other assets and provide full, cogent disclosure – Third‑party affidavits require documentary corroboration – Preservation of restrained assets for possible confiscation – Release for living expenses, strata arrears or child education refused where evidence insufficient.
23 March 2017