Stewart, Herman v Charles Higgins and Jamaica National General Insurance Company Ltd

Extensive delay satisfactorily explained-Erooneous information highly persuasive in grant of Order for substituted service-No full and frank disclosure of material facts-What constitutes reasonable efforts by an insurer to locate defendant varies-Each case turns on its peculiar facts-Court should be satisfied that contents of statement of case has come to defendant's attention before Order can be made-Order should be set aside where reasonable efforts to locate defendant have failed-Reasonable efforts must not be so onerous as to be unrealistic to achieve-Steps taken displayed reasonable efforts-Default judgement obtained on the mistaken basis that defendant was served must be set aside-Costs ordinarily follow the event.