Read the following scenario and answer the question that follows:

Ms Masina and Ms Seoke live in Protea Glen Estate in Soweto and have been neighbours for some time. Ms Masina does not care about the environment and regularly burns all her garden refuse by making a big fire. The fire smoke is a huge nuisance to Ms Seoke and makes life very unpleasant for her.

Which subdivision of the law of patrimony will be applicable to the fire smoke that makes life unpleasant for Ms Seoke?