On 24 June 2001, ABC Commandeer Corporate Services Ltd, a company based in the United Kingdom, caused the arrest of MS Ledwaba and attachment of several containers carrying engineering equipment while docked in the Durban Harbour. This action was in pursuance of a court order for the payment of an amount of US$750,000.00 owed to ABC Commandeer Corporate Services Ltd. Three months later, the containers were auctioned for US$700,000.00 in order to meet the consignor's debts. A referee was appointed to oversee the payment of the creditors of the consignment. Other creditors subsequently emerged after the auction, and made claims of varying amounts against the consignment. Chief among them was EFG Shipping Company Ltd, a company registered in Bahrain, which objected to the auction. EFG Shipping Company Ltd alleged that the consignment was sold to it in January of the same year 2001 when it was docked at a port in Saudi Arabia, and thus the ownership of the consignment resided in it as EFG Shipping Company. It further alleged that as a result, ownership of the consignment could not pass to a third party in order to satisfy the debt owed to ABC Commandeer Corporate Services Ltd.

QUESTION

In terms of the South African rules of private international law, which legal system would be applied to determine the validity of the transfer of ownership of the consignment in terms of the sale in execution in 2001? Discuss.