Competition Appeal Court - 2020

9 judgments
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9 judgments
Citation
Judgment date
November 2020
Reported
Crisis‑induced temporary market power can establish dominance; excessive pandemic price increases found but penalty avoided as de minimis.
Competition law — Excessive pricing (s 8(1)(a)) — Dominance and market power in crisis conditions — ‘Lucky monopolist’ concept — Prima facie case and onus under s 8(2) — Reasonableness factors under s 8(3) — Detriment to consumers — Penalty assessment and de minimis considerations.
18 November 2020
October 2020
27 October 2020
Mentioning prices at an industry meeting without consensus does not establish a binding price‑fixing agreement under section 4(1)(b)(i).
Competition law – s 4(1)(b)(i) – agreement/price‑fixing – consensus required that parties regard arrangement as binding; mere mention/price signalling insufficient; reliance on draft minutes and minute‑takers’ notes; proof delimited by pleadings; limitation/s 67(1) – prescription; evidentiary value of subsequent conduct.
21 October 2020
August 2020
Commission failed to prove the respondent’s continued participation in a cartel after change of ownership; appeal dismissed.
Competition law – s 4(1)(b) – alleged cartel and market allocation – whether attendance at pre‑Act meeting and subsequent information exchanges establish ongoing cartel membership; change of ownership and duty to speak; evidentiary standard: awareness and intent to contribute to cartel’s objectives; aggregated industry data insufficient to prove cartel participation.
7 August 2020
Reported
Withdrawal of a Tribunal referral completes proceedings under s 67(2), barring re-referral or reinstatement for the same conduct.
Competition law – Withdrawal of Tribunal referral – Meaning of 'completed' in s 67(2) – Jeopardy attaches on referral – Withdrawal completes proceedings and bars re-referral/reinstatement – Double jeopardy and abuse of process concerns.
3 August 2020
July 2020
Reported
A respondent may only appeal a Tribunal interim order if it has a final or irreversible effect on market competition.
Competition law — interim relief (s49C) — appealability — "final effect" and "irreversible effect" defined; interim order appealable only if it prevents final adjudication or causes irreversible competitive harm; costs order in interim proceedings constrained by s57 and Tribunal rules.
15 July 2020
February 2020
Whether the Competition Commission may assert jurisdiction over foreign banks for extraterritorial cartel conduct affecting South Africa.
Competition law – extraterritorial application – s 3(1) applies to conduct outside Republic with direct, immediate and substantial foreseeable effects in South Africa; Personal jurisdiction – common‑law development to recognise adequate connecting factors, appropriateness and convenience for assuming jurisdiction over peregrini; Declaratory relief – Tribunal may only grant orders where it has jurisdiction; Pleading – Commission required to file comprehensive new referral affidavit specifying facts to establish subject‑matter and personal jurisdiction; Joinder – deferred pending proper referral; Cross‑appeal – inclusion of non‑appealing respondent not an irregular step.
26 February 2020
Long-term tying arrangements were not proven to have foreclosed competition or caused higher prices.
Competition law – Exclusive dealing/tying – Foreclosure (actual and potential) – Burden of proof and role of market-share and machine-sales data – Counterfactual evidence – Pricing analysis – Insufficient proof of anti-competitive effect – Complaint dismissed.
25 February 2020
Reported
Whether the proposed hospital merger would substantially lessen local competition or be unjustifiable on public interest grounds.
Competition — Merger control: market definition — private multidisciplinary acute inpatient hospital services; exclusion of day-case services. Geographic market — local markets may be narrowly drawn; Potchefstroom and Klerksdorp are separate local markets. SSNIP and patient travel patterns — limited substitution across towns. Public interest (s12A(1)(b), s12A(3)) — price effects on insured/uninsured patients may justify conditions even absent SLC. NHN procurement exemption — material counterfactual reducing procurement-based harm. Actuarial evidence — admissible and capable of showing merger efficiencies. Remedies — behavioural remedies must be practicable, proportionate and enforceable
6 February 2020