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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27 judgments
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27 judgments
Citation
Judgment date
November 2020
Resentencing under the Parole Amendment: whole-life terms imposed for two murders involving premeditation, abduction and sexual/sadistic conduct.
Criminal law – murder – resentencing under Parole of Prisoners (Amendment) Ordinance s7 and s6A – whole-life minimum – aggravating factors: multiple murders, substantial premeditation and planning, abduction, sexual or sadistic conduct – forensic DNA and injury evidence – threshold for exceptional mitigating circumstances.
11 November 2020
October 2020
Transitional parole eligibility changes do not impose a heavier penalty on the applicant under section 6(4) of the Constitution.
Constitutional law – Retroactivity/Article 7 ECHR – Whether changes to parole eligibility constitute a heavier penalty – Distinction between penalty and execution of sentence – Parole of Prisoners (Amendment) Ordinance 2020 – Transitional re‑sentencing – Life imprisonment.
14 October 2020
September 2020
Civil Procedure
23 September 2020
14 September 2020
Foreign receivers by equitable execution may be recognised without domestication, but only on terms including payment of outstanding costs.
Conflict of Laws – Recognition of foreign receivers appointed by way of equitable execution; distinction between equitable execution and enforcement; Perry v Zissis inapplicable to recognition; sufficient connection/situs and forum considerations; officers of foreign court duties (directions, full and frank disclosure); effect of unpaid costs and abuse principle on permission to pursue fresh proceedings.
4 September 2020
Criminal law
4 September 2020
July 2020
Court allowed amendment for a misnamed defendant and granted limited pre-action disclosure of specified documents for a contemplated personal injury claim.
Civil procedure — Pre-action disclosure under s.10 CPO and Order 24 r.7A — Misnomer of defendant — Amendment allowed — Relevance and necessity of documents (CCTV, complaint records, first aider report, investigation reports) — Delay and absence of draft pleading not fatal.
28 July 2020
Court refused security for costs where plaintiff's safety-based confidential address and local assets made security unnecessary.
Civil procedure – Security for costs – Discretion under Order 23 – factors: non-residence, assets within jurisdiction, strength of claim, risk of oppression. Non-disclosure of address – justified by personal safety and foreign court confidentiality; non-disclosure not punitive. Assets within jurisdiction – shareholding in local company and company funds may suffice for enforcement. Merits – limited inquiry into strength of claim unless high degree of probable success or failure is shown.
17 July 2020
17 July 2020
Application for security for costs dismissed: defendant failed to prove plaintiff non‑resident or impecunious.
Security for costs – Order 23 r.1(1)(a) – non‑residency is a precondition but not determinative; court’s discretion to order security having regard to all circumstances; Residency – person may be resident in more than one place where property is readily available; Evidence and burden – applicant must prove non‑residency and lack of enforceable assets; Full and frank disclosure – material facts must be provided; Enforcement abroad – presumption of enforceability in Commonwealth/Canada absent evidence to contrary.
10 July 2020
June 2020
Regulation permitting Supreme Court sittings abroad is ultra vires to the extent it purports to extend territorial jurisdiction.
Constitutional law – Emergency regulations; Court sittings by video/remote means – limits on Supreme Court territorial jurisdiction; Ultra vires: emergency powers; Separation of powers; Ad hominem legislation; Section 20 (reasonable justification) and Article 7 (necessity, proportionality, urgency).
18 June 2020
Court refused defendant’s costs claim for wasted preparation, finding no unreasonable Crown conduct or prejudice to justify costs.
Criminal procedure – Costs in criminal proceedings – Jurisdiction of superior court to order costs – Supreme Court Ordinance s.3(1); Criminal Procedure Ordinance s.15. Inherent jurisdiction – Exercise sparingly to avoid clear injustice; guidance from English Practice Directions but not automatically adopted absent local rules. Application for judge-only retrial – late concession by Crown does not automatically attract wasted costs unless conduct caused prejudice or was unreasonable.
11 June 2020
Criminal law
5 June 2020
May 2020
Claim against a third‑party beneficiary struck out: privity and lack of pleaded liability mean no cause of action.
Contract law – privity and third-party beneficiaries – party to contract v. beneficiary; Civil procedure – strike out under Order 18 r 19(1) for disclosing no reasonable cause of action, frivolous or vexatious pleadings; Evidential limits – extrinsic affidavit evidence cannot cure pleading defects on strike-out; Entire agreement clause bars reliance on extrinsic matters; Abuse of process.
22 May 2020
Defendant sentenced to life with a 30-year tariff (less 628 days remand credit) under POPAO for firearm murder.
Criminal law – Murder – Sentencing under Parole of Prisoners (Amendment) Ordinance 2020 – Court must specify tariff before parole; starting point 30 years for murder unless "exceptional" circumstances; aggravating features (firearm, multiple shots, premeditation, public setting, group involvement); full credit for time on remand (628 days).
20 May 2020
Applicants awarded costs on standard basis after variation of restraint order; indemnity costs refused despite respondent’s procedural failings.
Proceeds of Crime Ordinance – restraint orders – variation to allow living and business expenses – costs: ordinary rule that costs follow the event; POCO ss.55,100,114 inapplicable to costs awards – indemnity costs require unreasonable conduct; late service and affidavits criticised but insufficient for indemnity.
19 May 2020
Banking
12 May 2020
1 May 2020
Defendant proved boat-rental set-off; business-licence and work-permit claims failed; net judgment and interest reformulated.
Counterclaim – set-off – loans consolidated; Boat hire – oral agreement, proved on balance of probabilities; Business licence – documentary evidence negates alleged licence arrangement; Work permit – no binding agreement or demonstrated acceptance/reliance; Registrar’s interest calculation set aside and replaced with court-ordered net sum with 6% interest.
1 May 2020
No binding 2008 lease was formed; 2012 lease valid and claim of economic duress dismissed.
Contract formation – necessity of agreement on essential terms and requirement of executed, vetted government lease before binding. Evidence – objective assessment of communications and conduct for intention to create legal relations. Tenancy – possession and rent where no concluded lease creates periodic tenancy. Economic duress – illegitimate pressure, practicable alternatives and bona fides; mere fiscal pressure not actionable. Intimidation and mistake – not established on the facts.
1 May 2020
March 2020
31 March 2020
31 March 2020
Costs
20 March 2020
Civil Procedure
10 March 2020
February 2020
Criminal law
20 February 2020
Constitutional Interpretation
7 February 2020
January 2020
Costs
15 January 2020