S v Mkabile (RCA 25/2023) [2025] ZAWCRD 7 (14 August 2025)

S v Mkabile (RCA 25/2023) [2025] ZAWCRD 7 (14 August 2025)

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Cited documents 5

Judgment
2
Reported
Refusal of lengthy postponement to secure counsel and use of section 342A did not breach applicants' fair-trial rights.
Criminal procedure – right to legal representation of choice – limits on postponement to enable accused to raise funds; Judicial impartiality – test for reasonable apprehension of bias; Unreasonable delay – statutory inquiry and remedies under s342A Criminal Procedure Act 51 of 1977; Application of s342A(3)(d) to deem defence closed where accused persistently seek extended postponement; Constitutional jurisdiction engaged where bias and s342A issues arise.
Reported
Claim that police search and investigative failures aggravated rape survivor’s psychiatric harm dismissed for lack of negligence and causation.
Police duty to search and investigate – standard of a reasonable organ of state; negligence versus wrongfulness in delict; factual and legal causation of psychiatric harm; limits on imposing liability for investigative omissions.

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