Høyesterett har nylig avsagt en dom om bortfall av sameieretter på ulovfestet grunnlag. Dommen er interessant fordi den forskyver det tradisjonelle synspunktet for når sameieretter kan anses bortfalt.

Det rettslige utgangspunktet:

Utgangspunktet er at en eier av fast eiendom, enten vedkommende er eneeier eller sameier, er eier av eiendommen frem til eierskapet avhendes ved salg, arv eller annet særlig rettsgrunnlag. Reglene om hevd innebærer at eierskapet i visse tilfeller også kan endres på grunn av lang tids bruk, forutsatt at vilkårene for hevd er oppfylt.

Norsk rett anerkjenner også at eiendomsrett kan opphøre på ulovfestet grunnlag i særlige tilfeller. Det avgjørende er om det – i det konkrete tilfellet – foreligger sterke grunner for å anse eiendomsretten som bortfalt. Høyesterett sine tidligere avgjørelser viser terskelen har vært meget høy. Følgende momenter har blitt tillagt betydning i vurderingen av om det foreligger tilstrekkelig sterke grunner for bortfall av eiendomsrett:

  • Partenes adferd og hvilket inntrykk denne skapte eller var egnet til å skape
  • God tro hos partene
  • Hvilken oppfordring hver av partene hadde til å handle
  • Tiden som er gått
  • Preg av festnet rettstilstand
  • Foretatte investeringer
  • Hva som vil være en rimelig løsning i den konkrete sak

Fast eiendom representerer en særlig viktig verdi både for den enkelte og samfunnet. Endringer i eierskap skjer i det praktiske liv ved formaliserte avtaler, ofte med profesjonell bistand. Hensynet til klarhet i eiendomsforhold tilsier at det bør oppstilles et strengt krav til hvilke grunner som kan innebære bortfall av eiendomsrett på ulovfestet grunnlag. Dette ble også presisert av dommens mindretall.

Saksforholdet i dommen:

I dommen var det tale om en hytteeiendom som var i sameie mellom flere parter. Sameiet ble opprettet i 1939, og hytten ble jevnlig brukt frem til 1960 tallet. Senere ble den mindre brukt blant annet på grunn av manglende vedlikehold. Ut over 1980 tallet var hytten uegnet som fritidsbolig på grunn av slitasje, og partene var enige om at den i praksis stod til nedfalls. I 1992 påbegynte den ene sameieparten rehabilitering som pågikk over 18 år. De andre sameierne brukte den ikke.

Partene var enig om at tomten fortsatt var i sameie, men den part som hadde foretatt rehabiliteringen mente at hytten var i hans eneeie på grunn av den omfattende rehabiliteringen han hadde foretatt. Ingen av de andre sameierne hadde protestert på rehabiliteringen, eller tatt del i kostnader ved denne siden 1990 – tallet.

Høyesteretts vurdering:

Flertallet i Høyesterett kom til at eiendomsretten for de øvrige sameierne var bortfalt, slik at den part som hadde foretatt rehabiliteringen var blitt eneeier av hytten. Dommen er avsagt under dissens, det vil si at dommerne hadde ulikt syn på resultatet. Flertallet synes å ha lagt stor vekt på verdiforholdet før og etter rehabilitering, i tillegg til at ingen av sameierne hadde protestert eller fortatt noe for å sikre sine rettigheter i løpet av en periode på ca 18 år. Selv om parten som foretok rehabiliteringen selv i utgangspunktet hadde oppfordring til å bringe klarhet i forholdene før han påbegynte arbeidet, mente flertallet at handleplikten etter hvert ble mer og mer skjøvet over på de øvrige sameierne. Dersom de mente å ha sine rettigheter i behold, burde de ha foretatt seg noe på et langt tidligere tidspunkt.

Konsekvenser av dommen:

Utgangspunktet er også etter dommen at det kreves sterke grunner for å anse eiendomsrett i fast eiendom som bortfalt, selv om terskelen kan synes noe lavere enn det som har vært tradisjonelt antatt.

Dommen viser at det er svært viktig med klare avtaler om hvilke konsekvenser en sameieparts påkostninger skal ha for de øvrige sameiere før eventuell rehabilitering av gamle bygg foretas. Dette gjelder særlig i de tilfeller bare en/noen av sameierne benytter eiendommen.

Ta kontakt med advokat Line Gjerstad Tjelflaat på lgt@tsadv.no eller 474 45 132 dersom du har spørsmål til fast eiendom.

 

 

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