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In this case, one of the most recent cases on the numerus clausus problem, a number of issues between the parties had to be decided. For purposes of this discussion, the focus will fall on only one, namely the registrability or not of two cond itions which originally appeared in a deed for the sale of a piece of land. In one of these clauses, (clause 6), it was provided that the land could only be used for the manufacture of armaments by the government for any defence or military purpose. In the other, (clause 7), the purchaser granted the seller the first right to repurchase the property In order to answer the question as to the registrability or not of these rights, the court again accepted as correct the two-stage approach described above. 49 This means that the court had to determine, first, whether it was the intention of the parties to create a real right and, secondly, whether the nature of the right was such that it would result in a subtraction from the dominium In casu, the court preferred first to apply the second criterion, the subtraction from the dominium'test. This test. in the words of the court entails the following: 50 One compares the right in question and the correlative obligation to see whether the obligation is a burden upon the land itself or whether it is something which is to be performed by the owner personally. If it is the former, the right is capable of being a real right. If it is the latter. it cannot be a real right. In order to ascertain whether the obligation is a burden upon the land two useful concepts which have been used are that the curtailment of the owner's rights must be something in relation to the enjoyment of the land in the physical sense . or that the obligations affect the land or run with the The application of the test to the two cond itions in question led to different results. With regard to clause 6(the restriction on the use of the land ) the court decided that the cond ition curtailed the right to use the land and that it therefore amounted to a subtraction from the dominium. It therefore"fell squarely within the definition'of section 63(1)of the Registration of Deeds Act 5I and could, in principle, be registered as a real right. The cond ition contained in clause 7(the first right to repurchase), on the other hand, did not constitute a subtraction from the dominium: 52 There is nothing in clause 7 of the agreement which affects the property or which curtails [the] right of enjoyment of the property in the physical sense Clause 7 was therefore clearly'not registrable 53 sEe sect. 2 above 50 At 435E-F. This exposition reflects the classic formulation of the subtraction from the dominium'test in Ex parte Geldenhuys 1926 OPD 155 at 164: see subsect. 3. 1 above 5 Act 47 of 1937. See subsect. 3.1 above 52At437I 53Clause 7 was also not registrable in terms of the proviso to sect. 63(1)of the Act as it was not"complementary or otherwise ancillary to another registrable right. Even if it could be registered in terms of the proviso, it would not have been converted into a real right: see n. 18 aboveIn this case, one of the most recent cases on the numerus clausus problem, a number of issues between the parties had to be decided. For purposes of this discussion, the focus will fall on only one, namely the registrability or not of two conditions which originally appeared in a deed for the sale of a piece of land. In one of these clauses, (clause 6), it was provided that the land could only be used for the ‘manufacture of armaments by the government for any defence or military purpose’. In the other, (clause 7), the purchaser granted the seller ‘the first right to repurchase the property’. In order to answer the question as to the registrability or not of these rights, the court again accepted as correct the two-stage approach described above.49 This means that the court had to determine, first, whether it was the intention of the parties to create a real right and, secondly, whether the nature of the right was such that it would result in a subtraction from the dominium. In casu, the court preferred first to apply the second criterion, the ‘subtraction from the dominium’ test. This test, in the words of the court, entails the following:50 One compares the right in question and the correlative obligation to see whether the obligation is a burden upon the land itself or whether it is something which is to be performed by the owner personally. If it is the former, the right is capable of being a real right. If it is the latter, it cannot be a real right. In order to ascertain whether the obligation is a burden upon the land two useful concepts which have been used are that the curtailment of the owner’s rights must be something in relation to the enjoyment of the land in the physical sense . . ., or that the obligations ‘affect the land’ or ‘run with the land’. The application of the test to the two conditions in question led to different results. With regard to clause 6 (the restriction on the use of the land), the court decided that the condition curtailed the right to use the land and that it therefore amounted to a subtraction from the dominium. It therefore ‘fell squarely within the definition’ of section 63(1) of the Registration of Deeds Act 51 and could, in principle, be registered as a real right. The condition contained in clause 7 (the first right to repurchase), on the other hand, did not constitute a subtraction from the dominium: 52 There is nothing in clause 7 of the agreement which affects the property or which curtails [the] right of enjoyment of the property in the physical sense. Clause 7 was therefore ‘clearly’ not registrable.53 49See sect. 2 above. 50At 435E-F. This exposition reflects the classic formulation of the ‘subtraction from the dominium’ test in Ex parte Geldenhuys 1926 OPD 155 at 164: see subsect. 3.1 above. 51Act 47 of 1937. See subsect. 3.1 above. 52At 437I. 53Clause 7 was also not registrable in terms of the proviso to sect. 63(1) of the Act as it was not ‘complementary or otherwise ancillary to’ another registrable right. Even if it could be registered in terms of the proviso, it would not have been converted into a real right: see n. 18 above
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