oa Comparative and International Law Journal of Southern Africa - The South African Sectional Titles Act and Israeli condominium legislation



It is widely recognised that some of the ideas incorporated in the South African Sectional Titles Act, especially the manner of calculating the participation quota, were drawn from Israeli condominium legislation. The purpose of this article is to discuss this and other similarities as well as the differences between the two statutes. Where possible, different approaches to the same practical problems are compared and evaluated. At the outset the historical background to each enactment and the reasons for introducing condominium are outlined. Thereafter, before comparing specific provisions of the two enactments, the dogmatic structure of the system of condominium adopted by each of these enactments are examined.


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