S v Ngcobo (SH 14/2019) [2019] ZAKZNRD 9 (3 October 2019)

S v Ngcobo (SH 14/2019) [2019] ZAKZNRD 9 (3 October 2019)

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Cited documents 4

Act
2
Citizenship and Immigration · Education · Environment, Climate and Wildlife · Health and Food Safety · Human Rights · International Law · Labour and Employment · Public administration
Judgment
2
Special leave granted; rape conviction overturned due to unreliable corroboration and failure to prove guilt beyond reasonable doubt.
* Criminal law – appeal – special leave under s 16(1)(b) Superior Courts Act – manifest failure of justice. * Evidence – sexual offences – assessment of complainant’s credibility where material contradictions exist. * Corroboration – J88 medical report insufficient alone to prove non-consensual intercourse; prosecution should call forensic medical examiner to explain findings. * Witness evidence – limited nighttime observations may be unreliable and insufficient to corroborate complainant. * Standard of proof – State must prove guilt beyond reasonable doubt; conviction unsafe where corroboration is unreliable.
Reported
Multiple penetrations in one encounter may be charged as a single rape; 15-year sentence upheld despite prescribed life option.
Criminal law – Sexual offences – Rape – Multiple penetrations during a single encounter may be charged as one count – Part I Schedule 2 read with s 51(1) prescribes life where victim raped more than once – adequacy of charge and warning ascertained in open court – substantial and compelling circumstances can justify lesser sentence.

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