A Cautionary Tale In Interim Injunctive Relief: Lessons From Dixon V Seymour

• Published date: 22 July 2026
• Subject Matter: Corporate/Commercial Law, Litigation, Mediation & Arbitration, Family and Matrimonial, Family Law, Court Procedure, Trials & Appeals & Compensation, Trusts
• Law Firm: Appleby
• Author: Alan Bercow and William Spence

In a recent judgment of Chief Justice Ramsay-Hale,¹ the Cayman Grand Court provided guidance on the necessary components of an application for interim injunctive relief. The ruling illustrates how an ex parte application may fail to satisfy the American Cyanamid^{2 t}est when unsupported by proper evidence.

Background: A Family Dispute Meets Interlocutory Procedure

The case arose in the context of a family dispute over a piece of land known as Block 25C Parcel 203 (Property).³ The Plaintiff, Ms Sandra Dixon (Ms Dixon), applied ex parte for an interim injunction restraining her niece, Ms Sabrina Seymour (Ms Seymour), from selling the Property or otherwise dealing with it. The Property had been transferred to Ms Seymour by her father, Mr Larry Seymour (Mr Seymour), who was in hospital with a terminal illness. Ms Dixon asserted that it was the intention of Mr Seymour that the Property would be registered in Ms Seymour's name only temporarily, with a view to helping her secure a loan. If the contemplated loan transaction were unsuccessful, there was said to be an agreement that the Property would be transferred back to Mr Seymour. In breach of this alleged agreement, Ms Seymour had taken steps to sell the Property to a third party.⁴

Ms Dixon accordingly sought an interim injunction to restrain the sale, pending the determination of substantive proceedings. The application was brought by Ms Dixon in her own name, on the basis that a power of attorney had been conferred on her by Mr Seymour. Ms Dixon also relied on extracts from Mr Seymour's Will, which directed that the Property should be sold, so that the proceeds could be distributed to various relatives (including but not limited to Ms Seymour).⁵

Key Judicial Findings

In rejecting the application, the Chief Justice made a number of...