Competition Appeal Court

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46 judgments
Citation
Judgment date
January 2025
16 January 2025
October 2024
The Competition Appeal Court may not, under section 173 or otherwise, transfer a Tribunal-commenced statutory review to itself.
Competition law – jurisdiction and procedure – whether the Competition Appeal Court may transfer a review initiated in the Competition Tribunal to itself; scope of section 173 inherent judicial powers; distinction between statutory reviews under section 27(1)(c) and PAJA/legality reviews; effect of Group Five decision on forum competence.
7 October 2024
April 2024
Reported
Whether coordinated JV bids by a majority partner amounted to per se price‑fixing or collusive tendering — appeal dismissed.
Competition Act s 4(1)(b) – horizontal versus vertical relationships; definition and status of joint ventures/partnerships as 'firms'; characterization of per se prohibitions (price‑fixing and collusive tendering) under ANSAC; counterfactual analysis for horizontality; hub‑and‑spoke and intra‑enterprise conspiracy doctrines; role of disclosure, deception and demonstrable harm in distinguishing naked cartels from ancillary coordination in JV bidding contexts.
26 April 2024
March 2024
Concurrent jurisdiction prevails: a NERSA maximum gas price does not preclude Competition Commission investigations into excessive pricing.
Competition law — concurrent jurisdiction — s 3(1A) Competition Act — sector regulator’s price determination under s 21(1)(p) Gas Act does not oust Commission’s jurisdiction — abuse of dominance (s 8(1)(a)) investigations valid despite NERSA maximum price — memorandum of agreement confirms cooperation.
5 March 2024
January 2024
Reported
Commission’s SOC referral failed to plead jurisdictional and connecting facts for many foreign and non‑trading respondents.
Competition law – alleged cartel in USD/ZAR market – single overarching conspiracy (SOC) pleading requirements – need to plead common anti‑competitive objective, intentional contribution and knowledge/foreseeability – distinction between subject‑matter and personal jurisdiction for peregrini – limits on joinder of holding companies and on adding parties after referral – appealability of jurisdictional rulings in interests of justice.
8 January 2024
November 2023
The Tribunal unconditionally approved four large mergers after finding no competition or public interest concerns.
* Competition law – merger control – unconditional approval where notified transactions do not substantially lessen competition or raise public interest concerns * Sector-specific considerations – motor vehicle dealerships and premises acquisitions; real-estate development rights; pharmaceutical distribution rights; pension-fund investment in property joint ventures * Merger assessment – vertical, horizontal and portfolio effects; assessment resulted in no required conditions
14 November 2023
October 2023
Reported
Review dismissed: Tribunal correctly found crisis-induced market power and excessive pricing; condonation refused.
* Competition law – excessive pricing – s 8(1)(a) and s 8(3) test – application of Consumer Protection Regulations (Reg 4) during national disaster. * Dominance – s 6 turnover threshold distinct from s 7 market-power inquiry; crisis-induced market power can render multiple suppliers dominant. * Procedural – condonation for late review requires full explanation and prospects of success. * Administrative penalty – CAC narrow interference standard absent misdirection or fundamental error.
13 October 2023
August 2023
Reported
Whether s49C(5) limits the Tribunal to a single six‑month extension and whether that limits access to courts under s34.
* Competition law – interim relief – s49C(5) – interpretation of "a further period"; whether limited to a single six-month extension or permits multiple six-month extensions. * Constitutional law – right of access to courts (s34) – statutes capable of two meanings must be read in the least restrictive, constitutionally compatible way. * Jurisdiction – Competition Appeal Court may decide constitutional issues arising under the Competition Act and grant just and equitable relief. * Remedy – matter remitted to Tribunal; interim interdict to maintain status quo pending Tribunal decision.
16 August 2023
July 2023
Parallel bank account closures alone do not establish a concerted refusal to deal or abuse of dominance without a pleaded theory of competitive harm.
Competition law – refusal to deal – whether parallel/sequential account closures amount to concerted practice (s 4(1)(a)) – need for pleaded theory of harm; Abuse of dominance (s 8(1)(c) and s 8(1)(d)(ii)) – requirement to show market power and vertical foreclosure or other anticompetitive effect; Interim relief – standard is prima facie case; appealability of interim Tribunal orders – final or irreversible effect and interests of justice; Lis alibi pendens – inapplicable where other forums consider different legal issues.
17 July 2023
May 2023
Court transfers Part B of Tribunal application to its roll, schedules procedural directions, and makes no costs order.
Competition law — inter-institutional case management — transfer of a part of a Tribunal-launched application to the Competition Appeal Court roll; procedural directions under section 38(2A)(e); timing contingent on Tribunal’s reserved determination; no order as to costs.
5 May 2023
March 2023
Reported
A review of a Commission referral was stayed until Tribunal discovery completes to prevent circumvention of disclosure rules.
* Competition law – judicial review – stay of review proceedings – inherent power of Competition Appeal Court under s 173 – interests of justice, prospects of success and balance of convenience. * Disclosure and discovery – Tribunal rules govern access to Commission investigatory records; disclosure generally at close of pleadings. * Stay justified to prevent circumvention of Tribunal procedural rules and unfair advantage to a respondent.
24 March 2023
November 2022
Reported
Prospective intervener entitled to meaningful participation and expert access where it can assist on merger competition and public interest issues.
Competition law – mergers – intervention in merger proceedings – scope of intervention and exercise of Tribunal's discretion – entitlement of prospective intervener to make submissions and lead evidence on merger-specific competition and public interest issues – access to confidential merger record by legal and economic advisors subject to confidentiality undertakings – balance between expedition of proceedings and assisting the Tribunal.
22 November 2022
4 November 2022
September 2022
Reported
A s53 participant must have sufficient procedural rights to meaningfully assist the Tribunal’s inquisitorial merger inquiry.
* Competition law – intervention under s53(c) – participant status and procedural entitlements; inquisitorial merger hearings (s52) – Tribunal's duty to investigate with an open mind; balancing assistance against expedition under Rule 46(2); access to Commission’s record subject to confidentiality; targeted applications for additional documents or witnesses permissible; blanket discovery/subpoena rights refused.
5 September 2022
August 2022
A wide interpretation of s38(2A)(d) allows suspension of part of a Tribunal order pending appeal to protect participation rights.
Competition Act s38(2A)(d) – suspension of Tribunal orders pending appeal/review – scope to suspend parts of orders; intervention and participation rights – ancillary procedural rights (discovery, subpoenas, access to record); peremption – conduct required to waive appeal rights; prospects of success – prima facie threshold.
3 August 2022
Reported
Whether a dominant broadcaster’s refusal to carry rival channels constitutes refusal to supply scarce services warranting interim relief.
Competition law — interim relief under s49C — abuse of dominance — s8(1)(d)(ii) refusal to supply scarce goods or services and s8(1)(c) exclusionary acts — whether a dominant pay-television platform constitutes a scarce broadcasting/distribution service — prima facie case, irreparable harm and balance of convenience — role of transformative objectives of Competition Act in interim assessments.
1 August 2022
July 2022
Reported
A written pre-hearing directive excluding expert evidence is appealable if final in effect and beyond a single member’s interlocutory power.
* Competition law – pre-hearing directives – exclusion of expert evidence – whether written directive is final in effect and appealable under s37. * Tribunal procedure – single-member powers under s31(5) – limitation to interlocutory orders; final decisions require a panel. * Appealability – final vs interlocutory orders – application of Zweni, Metlika and SCAW principles; effect, irreparable prejudice and interests of justice.
19 July 2022
Reported
Tribunal’s refusal to allow intervention on a speculative new‑entry theory was upheld for lack of evidential basis.
Competition — merger intervention — section 53(c)(v) — admission of third‑party participants — new‑entry (potential competition) theory of harm — evidential threshold versus speculation — tribunal’s inquisitorial powers — commercial interest insufficient to justify intervention — undue delay.
8 July 2022
June 2022
Reported
Horizontality under s 4(1)(b) must be assessed absent the impugned agreement; bidding alone does not establish collusive tendering.
Competition law — Characterisation under s 4(1)(b) — Horizontality must be assessed by counterfactual economic analysis (absence of the agreement) — Bidding alone or ‘holding out’ does not create a horizontal relationship — Collusive tendering requires conduct designed to avoid competition, not mere identical bids or disclosed collaboration.
30 June 2022
Reported
Tribunal has ordinary review powers; merging party bears burden to prove substantial compliance and merger-specific retrenchments require an objective nexus to merger incentives.
Competition law – review under s27(1)(c) and Rule 39(2)(b) – ordinary review powers; standard: lawfulness, reasonableness and procedural fairness – Rule 39(1) creates threshold of apparent breach; Rule 39(2)(b) places burden on merging party to prove substantial compliance – merger-specific retrenchments tested objectively by nexus to incentives of new controller (BB Investment test), not subjective causation/principal motivation.
17 June 2022
April 2022
Reported
Tribunal rightly refused to excise an admission from a consent order; customer cancellations are not exceptional circumstances.
Competition law – Consent agreements – Variation of Tribunal orders – Whether ‘exceptional circumstances’ can justify amendment – Predictable private consequences (contract cancellations) of admitted collusion do not qualify as exceptional – Role of section 27(1)(d) and res judicata in varying consent orders – Public‑interest and lack of representation insufficient to justify excising admissions.
8 April 2022
March 2022
Reported
Tribunal erred by demanding premature, excessive particularity of cartel allegations; market effects and inferences are for hearing.
Competition law – cartel allegations under s 4(1)(b)(i) – pleading standards – Tribunal Rule 15(2) – agreement vs concerted practice – permissibility of alternative pleading – market definition and effects assessed at hearing, not required in granular detail at referral stage.
25 March 2022
February 2022
Reported
Withdrawal from a sporadic bid‑rigging cartel need not be formally communicated; only the Tribunal may condone s67(1) delay.
Competition law – collusive tendering (bid‑rigging) – cessation of prohibited conduct; test for withdrawal from cartels in sporadic bid‑rigging contexts – no rigid requirement of formal/public distancing; statutory time‑limit s67(1) condonable under s58(1)(c) but condonation lies with the Competition Tribunal; appellate jurisdiction – CAC cannot grant condonation absent an application before the Tribunal; late condonation applications and litigation prejudice may warrant refusal.
10 February 2022
December 2021
Reported
Inferential circumstantial evidence cannot establish a per se cartel without proven primary facts and proper characterisation.
Competition law – Cartels and collusive tendering – Role and limits of inferential reasoning and circumstantial evidence in per se prohibitions; Characterisation – necessity of assessing horizontal versus vertical relationships before finding a s 4(1)(b) contravention; Burden of proof – Commission must prove primary facts and exclude plausible alternatives; Economic evidence – importance of expert analysis when relying on pricing patterns.
17 December 2021
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
October 2019
Applicant's broad long‑term exclusivity contracts constituted exclusionary abuse of dominance without sufficient efficiency justification.
Competition — Abuse of dominance — Section 8(d)(i) — Long‑term, broad exclusivity in standard contracts — Exclusionary act; effects‑based inquiry — substantial/likely foreclosure sufficient; two‑sided platform dynamics; efficiency defence must show relationship‑specific, non‑contractible gains and less restrictive means.
19 October 2019
July 2019
Identical bids by closely related firms do not equal collusive tendering absent an agreement or independent controllers.
Competition law – section 4(1)(b) – price-fixing and collusive tendering – characterisation required; section 4(5)(b) exemption – 'single economic entity similar in structure' to holding company/wholly-owned subsidiary – interpretive weight to Companies Act 2008 control-test; identical bids by commonly administered firms do not automatically establish collusion without an agreement or concerted practice.
2 July 2019
The applicant failed to prove post‑Act implementation of a pre‑Act market‑allocation agreement; appeal dismissed.
* Competition Act s 4(1)(b)(ii) – market allocation – requirement to establish existence and implementation/continuing conduct after commencement of the Act.* Characterisation – horizontal versus vertical relationship – objective assessment of economic substance.* "Agreement" in competition law – consensus suffices; implementation evidence often central to proof of continuing contravention.* Economic successor liability – requires pleaded and proven evidentiary basis for transfer of liability.* Pre‑Act regulation (GN 801) proscribing market sharing – raised but not decided as unnecessary to outcome.
2 July 2019
May 2019
Whether the Tribunal properly balanced s12A(3) public‑interest employment concerns when approving a major mining merger.
Competition law – Mergers – Public interest under s12A(3) – Employment impact – Distinction between merger‑specific and operational retrenchments – Rationality and counterfactual inquiries – Conditions on merger approval – Locus standi to appeal Tribunal merger decisions (s17) – Admission of new evidence on appeal.
17 May 2019
April 2019
Reported
Section 67(1) is a three‑year limitation from cessation of the prohibited practice and is not subject to condonation.
Competition Act s.67(1) – limitation/expiry period measured from cessation of prohibited practice – no knowledge requirement – no scope for Tribunal condonation; initiation/amendment of complaints – whether later initiation extends earlier initiation; pleaded discrete bilateral agreements may be treated as separate practices for limitation analysis.
3 April 2019
October 2018
s13A(3) bars implementation of control pending approval; voting of acquired shares is only restricted if those shares confer control.
Competition law – Merger control – s13A(3) prohibits implementation of an intermediate or large merger pending approval but does not, without evidence of control, prohibit voting shares acquired after a firm intention – De facto control under s12(2)(g) is fact‑specific – Goldfields distinguished.
29 October 2018
Commission failed to prove privilege; respondents entitled to transcripts and specified correspondence disclosure.
Competition law – disclosure and discovery – litigation privilege – privilege requires factual averments showing documents were created for contemplated or pending litigation; leniency materials not automatically privileged; Commission Rule 14/15 are public‑access provisions and cannot be used to deny respondents in referral proceedings discovery absent proof; Tribunal erred in withholding interrogation transcripts and correspondence.
17 October 2018
September 2018
An agreement extending a referral deadline under the Act governs filing time; Tribunal rules cannot render a valid, in‑time referral invalid.
Competition law — referral of complaints under section 50(2) and extensions under section 50(4)(a) — interaction with Tribunal Rules (rules 4(1), 4(2), 6(4), 8(2), 14(3)) — registrar's out‑of‑hours acceptance — rules cannot override statutory referral periods — condonation of technical non‑compliance.
17 September 2018
May 2018
Rule 15(1) grants any person public access to the Commission's investigation record; litigant status does not affect reasonable-time assessment.
Competition law — Access to Commission records — Interpretation of Competition Commission Rule 15(1) — Public right of access irrespective of requester’s litigant status — Rule 14(1)(e) and PAIA s.7 not operative to exclude access — Tribunal misdirected by factoring litigant status into "reasonable time" assessment — abuse of process not established.
17 May 2018
Reported
An ancillary non‑compete in a shareholders agreement, reasonably required to protect confidential information, did not contravene s 4(1)(b)(ii).
Competition law – Section 4(1)(b)(ii) – Non‑compete in shareholders agreement – Characterisation of restraint – Ancillary restraints test: main transaction unobjectionable; restraint reasonably required and proportionate – Horizontal relationship (potential competitor) – Evidentiary standard for motion proceedings (Plascon‑Evans) – Burden of proof on referring party.
4 May 2018
April 2018
Tribunal has jurisdiction to hear abuse-of-dominance and essential-facility claims even when arising from statutory port decisions.
* Competition law – Jurisdiction – concurrent jurisdiction of competition authorities and other regulators – s 3(1A)(a) – Competition Act applies to all economic activity. * Competition law – Abuse of dominance – refusal of access to essential facility – s 8 – exclusionary acts. * Administrative/public law – statutory exercise of powers under National Ports Act does not automatically oust competition jurisdiction. * Procedural law – Tribunal’s exception for lack of jurisdiction dismissed; Tribunal should adjudicate Chapter 2 complaints.
25 April 2018
Reported
Subpoenas for ITAC/DTI‑related documents were set aside for lack of demonstrated relevance and improper circumvention of ITA confidentiality.
Competition law – subpoena duces tecum – relevance and necessity for pending referral – abuse of Tribunal process; Confidentiality – International Trade Administration Act (ITA Act) – ITAC and High Court role in confidentiality determinations – Tribunal cannot bypass statutory regime; Civil procedure – scope of affidavits and settlement undertakings; Costs – appellate review of Tribunal's discretion.
3 April 2018
March 2018
Reported
AAC, not ATC-plus-intent, governs s 8(c) predatory-pricing claims; the respondent failed to prove predation.
Competition law – Predatory pricing – s 8(d)(iv) adopts marginal/average variable cost (AVC) benchmarks – s 8(c) is an objective exclusionary provision – ATC-plus-intent test inconsistent with s 8(c) – AAC is the appropriate benchmark for s 8(c) predation claims – opportunity costs/foregone profits not to be included in AAC – inclusion of redeployment, allocated common, printing and distribution overheads must be proven avoidable.
19 March 2018