Judicial Committee of the Privy Council

This is the final court of appeal for the Turks and Caicos Islands.

To take an appeal to the Privy Council, the appellant must have been granted leave by the Court of Appeal whose decision is being appealed. In the absence of leave, permission to appeal must be granted by the Privy Council. In some cases, there is an appeal as of right and a slightly different procedure applies.

The Privy Council also has the jurisdiction, under section 85(6) of the Constitution to consider a request of the Governor under s 85(7) of the Constitution to remove a judge or Magistrate from office.

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17 judgments
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17 judgments
Citation
Judgment date
January 2023
Criminal law
31 January 2023
November 2020
Emergency Regulations permitting a judge to sit remotely are valid; remote judging not inherently unfair, trial judge to assess fairness.
Constitutional law – judicial sittings – interpretation of emergency regulations permitting remote hearings; statutory construction and purposive approach; limits on subsidiary legislation where Constitution implies forum is territorial; criminal procedure – fair trial and inequality of arms – remote judging not per se unfair; case‑management discretion of trial judge; inherent jurisdiction – remote participation permissible where hearing takes place in territorial courtroom.
13 November 2020
December 2017
A one‑month minimum rental by‑law validly regulates residential use, not unlawfully restricting alienation.
Strata title – by‑law construction – restriction on use v. restriction on alienation – s.20(4) validity – one‑month minimum rental to preserve residential character – short‑term holiday letting.
21 December 2017
March 2017
A knowing recipient of undervalued property may be treated as constructive trustee and must account for profits, not just the undervalue.
Equity – Knowing receipt – Requirements: disposal in breach of fiduciary duty; recipient’s beneficial receipt of assets traceable to that disposal; recipient’s knowledge – El Ajou/Arthur applied. Constructive trust – Land acquired at undervalue may be treated as trust asset; recipient liable to account. Account of profits – Liability arises from making a profit in breach of fiduciary duty, not from proof of loss or causal link to specific profits. Proprietary v personal remedies – Both available; claimant not confined to monetary undervalue.
27 March 2017
June 2015
Ad hoc appointment did not undermine judicial independence; judge-alone trial decision is an evaluative balancing, not a criminal-standard proof matter.
Constitutional law — right to a fair hearing by an independent and impartial court — security of tenure and ad hoc judicial appointments. Judicial independence — individual and institutional independence; role of an independent Judicial Service Commission. Criminal procedure — trial without jury under statutory "interests of justice" test is an evaluative balancing exercise, not governed by the criminal standard of proof. Evidence/admissibility distinction — factual preconditions requiring proof vs evaluative judicial judgments in the interests of justice.
25 June 2015
October 2014
Regulatory powers and licensing procedures govern spectrum rights; ISM AMR meters did not require spectrum or carrier licences.
Telecommunications law – spectrum allocation – validity of licence amendments – necessity of statutory procedures for allocation; Spectrum management – ISM bands – exemption from spectrum-licence requirement; Carrier licences – definition of "telecommunications network" – standalone AMR meters not a network; Statutory interpretation – reading licensing provisions in context to avoid irrational results.
16 October 2014
March 2013
Underpayment of stamp duty does not create a registrable charge and a s132 restriction entered without independent inquiry is unlawful.
Registered land – Restriction (s132) – Registrar’s discretion and duties to make inquiries – Stamp duty underpayment does not create proprietary charge absent express statutory declaration (s28(e)) – Proper remedies: in personam judgment, charging order, or rectification for fraud/mistake – Invalidity of restriction entered solely on applicant’s erroneous claim.
14 March 2013
August 2012
The RLO does not bar constructive-trust claims for knowing receipt where a registered transferee acted in bad faith.
Land registration (Torrens) – Registered Land Ordinance – proviso (i) s23 – sections 38(2) & 122(3) – knowing receipt/constructive trust – equitable fraud/bad faith – rectification (s140) – indefeasibility exception.
16 August 2012
May 2012
Commissioner could make provisional findings about implicated third parties; overall procedure was not unfair.
Commissions of Inquiry – terms of reference – scope to investigate persons "in relation to" elected officials; provisional fact‑finding and recommendations for criminal investigation permitted; procedural fairness – Salmon principles apply flexibly; s7 Ordinance entitlement to representation and to be treated as a person whose conduct is subject of or implicated in inquiry; where a reasonable opportunity to give oral evidence is offered and substantial written submissions are considered, there is not necessarily unfairness requiring removal of findings.
23 May 2012
January 2010
Letters and negotiations did not create a binding land development contract or proprietary estoppel; appeal dismissed.
Contract law – formation – governmental letter of comfort and subsequent conduct – requirement of intention and certainty of essential terms before a binding development agreement; approvals by Executive Council and Governor. Proprietary estoppel – need for representation giving rise to a reasonable expectation of a certain proprietary interest, detrimental reliance and unconscionability; Yeoman’s Row applied. Civil procedure – discovery – additional documents/affidavits cannot cure fundamental absence of estoppel elements. Costs – trial judge’s discretion; limits on awarding costs against successful defendant (Ritter v Godfrey).
21 January 2010
December 2009
Tariff category during a hotel's first year must be provisional and adjusted once its first 12‑month consumption is established.
Electricity regulation — tariff categories defined by annual consumption — validity of retrospective rolling 12‑month assessment; provisional billing and retrospective adjustment required for a customer's first 12 months.
13 December 2009
July 2009
Beneficiary's contractual trust rights did not make it a creditor entitled to present a winding-up petition.
Companies law – winding up petition – locus standi – creditor requirement; Reinsurance and trust arrangements – distinction between present debt and security for contingent/unearned reserves; Trust law – beneficiary withdrawal rights, equitable interest and bare trust; Petitionable debt – need for liquidated claim or entitlement to payment directly from alleged debtor.
15 July 2009
May 2009
A remuneration dispute based on alleged promises to a public officeholder is a private law claim, not a judicial review matter.
Judicial review – Appropriate procedure for remuneration disputes – Private law (contract/estoppel) claim versus public law remedies (legitimate expectation) – Case management discretion whether to grant leave or convert to an action – Need for pleading, discovery and oral evidence.
21 May 2009
June 2004
Taxation of solicitor’s bills allowed on quantum meruit; conditional fee agreement not proved and variation permissible but elective to paying party.
Costs — taxation between party and party — implied retainer and quantum meruit — validity and effect of post‑order variation to fee arrangement — conditional fee agreements (whether proven and public policy) — taxing officer to assess hours and reasonable rates.
24 June 2004
Taxation of litigation costs may proceed on quantum meruit; alleged conditional fee agreement not proved.
Civil procedure – Costs – Taxation of solicitor's bills – quantum meruit where charging terms uncertain Contract – Implied contract for remuneration – Way v Latilla principle applied Conditional fee agreements – allegation must be proved; not established on these facts Variation of fee arrangement – substitution of calculation method and consideration Indemnity principle – recoverable costs limited to what receiving party is liable to pay, assessed reasonably
24 June 2004
July 2001
AAA institutional rules permitted the award as a "reasoned award," but arbitrators lacked jurisdiction to join and award a non‑consenting affiliate.
Arbitration – institutional rules (AAA) govern form and procedure where incorporated – meaning of "reasoned award" under AAA; Joinder – institutional/contractual clauses limiting consolidation/joinder do not confer power to add non‑consenting non‑parties; Party autonomy and consent remain fundamental; Award enforcement – award to contracting party upheld despite affiliated performance.
16 July 2001
March 1906
Parol evidence can prove additional consideration, but an ordinary agency is revocable and equity will not enforce personal service.
Parol evidence – admissible to prove additional consideration not contradicting a written instrument; Agency – authority coupled with an interest; revocability of agency; Equity – injunction/specific performance not available to enforce personal service in ejectment.
21 March 1906