Real Estate Investor Magazine South Africa February/March 2019 | Page 8
Q&A
Property Advice
CILNA STEYN
Managing Director, SSLR Attorneys Incorporated
Q
Mark Saunders, Johannesburg
I am a landlord struggling with non-paying
tenants, I use prepaid meters for electricity in all my
properties. The meter reading company I use told me
that they can load any arrear rental payments onto the
electricity meter, which will mean that the tenant must
pay the rent before he can buy electricity. This sounds
like a great way to collect rent, but is this legal?
A
Cilna Steyn, SSLR Attorneys
Prepaid utility meters have changed the working of
rentals substantially. For a very long-time municipalities
allowed tenants to register the accounts in their own names,
this was changes by most municipalities over the past few
years, at this moment most municipalities will only keep the
owner of the property responsible for the utility account.
This left many owners with their hands in their hair. The
popularisation of prepaid meters changed this position, by
using prepaid meters landlords will not run into high unpaid
utility bills from the municipality without the ability to
collect this from the tenant, should the tenant abscond or
default on rental payments. Many meter reading companies
allows landlords to load any payments onto the meters,
which will mean that there will be a credit on the particular
account which has to be paid before electricity or any other
utility services can be purchased.
At this point it is crucial to first consider the relationship
between occupation of a premises and utility supply to a
property. Physical occupation of an immovable property is
only an element of possession of the property. Possession of
immovable property is more complex than just physically
being in the property, in that you do not necessarily have
to occupy in person. In other words, you do not have to
physically live in the property to occupy the property, you
might be in possession by merely having the keys and the
right to occupy, whether you then occupy or not does not
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EXPERTS
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change the fact that you have possession of the property.
Utility supply might not seem like something a person
can be in possession of, because utilities cannot be possessed
as such. However, considering the nature of immovable
property, utility supply to the premises is a very crucial
part of possession of immovable property. We have seen
in many court cases that the courts consider utility supply
to be incidental to occupation. If we pause at this point to
consider this, it becomes clear that without utility supply to a
property, occupation is still possible, but is made nonsensical.
The reason why we are discussing possession is to consider
a question of the reader, we need to discuss the effect on
possession when disallowing the tenant to purchase
electricity until the arrear rental has been paid. The act of
depriving another person from possession is called spoliation
and all courts have jurisdiction to grant a spoliation order
and order that the person that was deprived of possession
be placed back in possession. The possession referred to
when discussing spoliation is possession of movable as
well as immovable property, and crucial to this point is
that the possession does have to be lawful possession to be
afforded protection by this remedy. In other words, an illegal
occupant’s possession cannot be disturbed in any way. The
only way to legally deprive a person of any possession is by
obtaining a court order.
Loading arrear rental onto an electricity meter would
mean that the tenant is effectively deprived of possession,
by disallowing them to purchase prepaid services which will
be nothing other than spoliation. As creative as this solution
might be it is illegal and if dealt with by a court of law the
landlord will be compelled to place the tenant back in a
possession to have the full utility supply. In most cases the
landlord will also be ordered to pay the tenant’s legal cost for
spoliation application. I will always advise to stay away from
any for of arbitrary evictions.
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FEBRUARY/MARCH 2019 SA Real Estate Investor Magazine