Before the decision of the Supreme Court of Appeal in Paulsen v Slip Knot Investments (434/13) [2014] ZASCA, there was uncertainty on whether the in duplum rule applied only to default interest, being interest accrued on a capital amount which has fallen due for payment but has not been paid, or whether it also applied to interest accrued on capital which has not yet become payable. The Supreme Court removed this uncertainty by finding that the in duplum rule applies in both cases.