In Bezuidenhout v Mutual Insurance Ltd 1987 (1) SA 703 (A) the court held the following:

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If the provision is formulated in flexible or vague terms, it is an indication that it is directory

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A word or words with an imperative or affirmative character indicate a peremptory provision

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The word shall is a strong indication that the provision is peremptory

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Words in a negative form indicate a peremptory connotation

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