High Court of South Africa Eastern Cape, Bhisho

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163 judgments
Citation
Judgment date
November 2025
Court refused to develop common law for undertaking-to-pay remedy and awarded a lump-sum for future medical care.
Delict — future medical expenses — whether common law should be developed to permit undertaking-to-pay or in-kind relief — pleadings and cogent factual evidence required — case-by-case inquiry; public-healthcare remedy; enforceability, budgeting and implementation concerns; award of lump-sum, interest, trust and costs.
18 November 2025
No substantial and compelling circumstances found; life sentence imposed for murder linked to aggravated robbery; s204 witness discharged.
Criminal law – Minimum Sentences Act – s 51(1) murder linked to robbery with aggravating circumstances – substantial and compelling circumstances required to deviate – sentencing triad – elderly victim killed in home – s 204 witness discharged after frank and honest testimony.
18 November 2025
Court applied minimum‑sentence regime, fixed a s276B non‑parole period for recidivist leader and imposed correctional supervision for a peripheral offender.
Sentencing — minimum sentences (Criminal Law Amendment Act s51(2)) — substantial and compelling circumstances — section 276B Criminal Procedure Act (non‑parole period) — correctional supervision s276(1)(h) and s276A — s103 Firearms Control Act (declaration of unfitness) — concurrency and cumulative sentencing — recidivism and parole revocation.
18 November 2025
October 2025
Initial arrest lawful; continued detention not shown to result from malicious police or prosecutorial conduct.
Constitutional right to freedom and protection against arbitrary detention; lawful arrest on reasonable suspicion (s 40(1)(b) CPA); exercise of police discretion; lawfulness of initial detention until first court appearance; joinder and addition of charges (ss 81–83 CPA); bail proceedings and interests of justice (ss 50, 60 CPA); malicious deprivation of liberty—requirements of absence of reasonable and probable cause and animus iniuriandi; causation for state liability for continued detention.
28 October 2025
Absent evidence, a public-healthcare defence cannot displace the lump-sum damages rule; lump-sum award and trust ordered.
Public-healthcare defence; undertaking-to-pay remedies; once-and-for-all lump-sum damages rule; requirement to lead cogent evidence to justify in-kind or periodic remedies; entitlement to actuarialised future damages; creation of special trust and payment within 30 days.
14 October 2025
Court accepted an accomplice’s credible evidence and convicted the accused of murder, housebreaking and robbery with aggravating circumstances.
Criminal law – murder – single accomplice witness (minor) – application of cautionary rule and corroboration; housebreaking with intent to steal; robbery with aggravating circumstances – circumstantial evidence and R v Blom test; assessment of alibi and credibility.
10 October 2025
Reconnection relief held moot; court orders municipality to answer applicant’s section 102 account dispute within 60 days.
Mootness—application for reconnection rendered academic where electricity restored; Municipal law—section 102 dispute: municipality obliged to answer disputes on accounts; Administrative law—failure to answer account dispute constitutes procedural unfairness warranting remedial relief; Costs—successful limited relief entitles applicant to costs on Scale A.
2 October 2025
Court convicted multiple accused of murder, kidnapping and public violence based on common purpose and credible evidence.
Criminal law – Murder; kidnapping; public violence – Doctrine of common purpose – prior meetings and active association – sufficiency of eyewitness, police and medico‑legal evidence – disassociation and withdrawal – public violence not duplicative of murder.
2 October 2025
September 2025
Applicant facing credible threats entitled to interim protective services pending review to safeguard life and bodily integrity.
Urgent interim interdict – prima facie right to security/protection – right to life and bodily integrity – irreparable harm – balance of convenience. Rule 6(12)(a) URC – condonation of non‑compliance with service/time in urgent applications. Confidentiality breach of Threat and Risk Assessment increases security risk and informs need for interim protection.
25 September 2025
Condonation granted for failure to serve statutory notice where good cause shown and respondent failed to prove prejudice.
Administrative / Constitutional law – Institution of Legal Proceedings Against Certain Organs of State Act 40 of 2002 – condonation under s 3(4) for failure to serve s 3(2)(a) notice. Civil procedure – requirements for condonation: non-prescription, good cause, absence of undue prejudice. Reliance on previous attorney’s dilatoriness and prompt action by new attorneys can constitute good cause. Interpretation – purposive, constitutionally-informed approach; right of access to courts relevant to condonation applications.
23 September 2025
Unmonitored intrapartum care breached duty of care and, on probabilities, caused the child’s hypoxic-ischaemic brain injury; defendant 100% liable.
Medical negligence; obstetric care; failure to assess and monitor labour per maternity guidelines; intrapartum hypoxic-ischaemic encephalopathy; expert evidence and causation on probabilities; defendant 100% liable.
9 September 2025
Whether substantial and compelling circumstances justify departure from minimum sentences under section 51.
Criminal procedure – plea under s 112(2) – adequacy of factual matrix to support conviction and reliance on s 51 Minimum Sentences Act; Minimum Sentences Act s 51 – murders in course of robbery and jurisdictional facts; Sentencing – role of intoxication, youth, remorse and re‑offending on bail; Sentencing principles – Zinn triad, substantial and compelling circumstances; Victim support – court-ordered counselling; Firearms control – declaration of unfitness under s 103.
4 September 2025
August 2025
An appeal against conviction and life sentence for murder and related offences was dismissed, confirming proper application of common purpose and sentencing principles.
Criminal law – Murder, robbery with aggravating circumstances, attempted murder – Common purpose – Identification – Intoxication as defence – Minimum sentences – Appeal against conviction and sentence – Application of common purpose doctrine – Reliability of identification – Sentencing discretion and substantial and compelling circumstances.
12 August 2025
Police officers’ arrest and detention of the applicant for rape was lawful, based on reasonable suspicion and proper exercise of discretion.
Unlawful arrest – arrest without warrant – section 40(1)(b) Criminal Procedure Act – reasonable suspicion – exercise of police discretion – post-arrest detention – quantum of damages – claims for unlawful arrest and detention dismissed.
12 August 2025
An unjust enrichment claim against an organ of state is not a "debt" under Act 40 of 2002; notice requirement therefore inapplicable.
Constitutional and procedural law – Court may raise a point of law mero motu; Administrative/contractual claims – Unjust enrichment is not a "debt" under Institution of Legal Proceedings against Certain Organs of State Act 40 of 2002 and does not require the Act’s six‑month statutory notice; Pleadings – Proper characterisation of cause of action (enrichment v negligent omission) determines applicability of Act; Prescription – suitability of adjudication at interlocutory stage.
4 August 2025
July 2025
Hospital staff’s negligence in labour management found to have caused a child’s hypoxic brain injury, establishing liability for damages.
Medical negligence – Causation – Hypoxic ischaemic brain injury at birth – Causal link between sub-standard obstetric care and cerebral palsy – Expert medical evidence – Assessment of conflicting pediatric opinions – Liability for damages in representative capacity.
29 July 2025
June 2025
Future medical negligence compensation requires specific criteria to apply non-lump sum payments.
Medical Negligence – compensation – development of common law – undertaking to pay remedies – public healthcare defense abandonment
27 June 2025
Court affirms mother's standing and compliance, directing the Fund to process the child's injury claim under RAFA.
Road Accident Fund Act – Locus standi – Registration compliance – Court's authority over administrative excuses by the Fund.
13 June 2025
Appeal upheld due to magistrate's arbitrary refusal of bail lacking evidentiary consideration.
Criminal Law – Bail refusal – Appeal – Whether magistrate's decision was wrong – Consideration of all relevant evidence and proper judicial reasoning required.
12 June 2025
State respondents’ delayed compliance with pension-order constituted civil contempt and breach of constitutional obligations; costs awarded to applicant.
Contempt of court – Civil contempt for failure to comply with administrative orders – State organ’s constitutional duty to comply diligently and without delay (ss 2, 165(5), 237) – Proof and onus in civil contempt (service, non-compliance, wilfulness; inference and rebuttal) – Costs: party-and-party; counsel costs taxed on Scale C (Rules 67A and 69).
3 June 2025
May 2025
Applicant complied with notice requirements; respondent's opposition deemed unnecessary and obstructive.
Civil Procedure – Institution of Legal Proceedings against State – Compliance with statutory notice requirements – Prescription period – Condonation for late notice filing.
15 May 2025
Applicant’s notice under ILPACOSA held timely; prescription delayed until legal advice, condonation alternatively granted.
Administrative law; civil procedure – statutory notice under ILPACOSA s3(2) – timing and compliance; Prescription Act s12(3) – actual and imputed knowledge in medical negligence claims; condonation under ILPACOSA s3(4) – requirements (no extinguishment by prescription, good cause, no unreasonable prejudice); allowance of supplementary affidavit; costs against organ of state.
15 May 2025
Condonation granted for technical non-compliance; applicant allowed to pursue claim as no prejudice to respondent.
Civil Procedure - State Liability Act compliance - Summons service - Condonation for procedural non-compliance granted.
13 May 2025
April 2025
An internal investigative report making conclusive adverse findings was reviewable and set aside for procedural unfairness and overreach.
Administrative law – internal investigation – whether an investigatory report making conclusive adverse findings constitutes reviewable exercise of public power under the principle of legality/PAJA. Principle of legality – overreach of investigatory mandate where investigator pronounces on culpability. Procedural fairness – audi alteram partem and legitimate expectation to be heard; necessity of meaningful opportunity and disclosure of documents. Mootness – completion of investigation does not necessarily render review inappropriate where practical consequences remain. Remedy – review and setting aside of procedurally tainted report; costs awarded including counsel’s fees on Scale C.
5 April 2025
March 2025
Section 174 discharge refused: State proved a prima facie case of kidnapping, assault with intent to do grievous bodily harm and murder.
Criminal procedure – Section 174 CPA – discharge at close of State case – test is whether there is evidence upon which a reasonable person might convict (prima facie case); Kidnapping – unlawful deprivation of freedom of movement by forcible control and relocation; Assault with intent to do grievous bodily harm – repeated application of force with hands, feet and blunt implements; Murder – death by blunt trauma to the head consistent with assaults; Credibility – limited role at section 174 stage, adverse credibility findings premature unless evidence is inherently unbelievable.
14 March 2025
The appeal succeeds due to the appellant's reasonable delay explanation and good prospects of success in the main action.
Legal procedures – condonation of late notice – unsophisticated layman – unlawful arrest – prima facie burden on respondent.
4 March 2025
February 2025
Conviction under s67A without a separate charge is irregular; proper s67(3) enquiry requires reinstatement of bail and setting aside conviction.
Criminal procedure – Failure to appear while on bail – Distinction between summary enquiry under s67(3) and prosecution under s67A of the Criminal Procedure Act – Conviction without separate charge invalid – Conviction and sentence set aside on review.
11 February 2025
Contempt application dismissed due to defective PAIA order, inadequate service/notification and attempt to compel non-existent records.
Administrative law – Promotion of Access to Information Act (PAIA) – procedural requirements for notices and set down – State Attorney reference and Rule 23(m) – effect of service over court recess (Uniform Rule 6(5)(b)(iii)) – contempt proceedings – inability of PAIA to compel non-existent records – use of Rule 42 to correct orders.
7 February 2025
January 2025
A purchaser who has paid at least 50% cannot rely on s 27(1) to demand transfer once the sale has been validly cancelled.
• Property law – Alienation of Land Act 68 of 1981 s 27(1) – rights of purchaser who has paid at least 50% – requirement of an extant contract and/or demand for transfer. • Contract law – cancellation – effect of valid cancellation on purchaser’s statutory remedies under s 27(1). • Civil procedure – disputes of fact on affidavit – stringent test for referral to viva voce evidence. • Costs – discretion to award punitive costs only where justified; substitution with party-and-party costs where no basis for attorney-and-client order.
28 January 2025
Property ownership claims must demonstrate a clear right; past events cannot be interdicted through appeals.
Property Law – Interdictory relief – Requisites for final interdict – Failure to demonstrate clear ownership rights – Procedural delay in appeal reinstatement.
22 January 2025
Whether permanent appointments of foreign nationals by an unauthorised official, contrary to s10 PSA and policy, are unlawful and what remedy is just and equitable.
• Administrative law – legality doctrine – organs of state may exercise no power beyond that conferred by law; appointments contrary to clear statutory prohibition unlawful. • Public Service Act s10 – permanent appointment limited to South African citizens or permanent residents; foreign nationals may only be employed temporarily in terms of policy. • Self-review by State – undue delay in instituting review measured by Khumalo/Asla principles; nonetheless clear illegality may require declaration of invalidity. • Remedies – section 172(1)(b) discretion to craft just and equitable relief including suspended declarations to mitigate prejudice.
21 January 2025
December 2024
Appellants failed to prove exceptional circumstances for bail on Schedule 6 charges; magistrate’s refusal upheld.
Criminal procedure – Bail – Schedule 6 offences – Onus on accused to show exceptional circumstances under s60(11)(a) – Interests of justice enquiry. Magistrate’s discretion – limited appellate interference unless decision was wrong per s65(4). Strength of State case – prima facie case established by vehicle identification and recovery of firearms. Procedural issues – answering affidavits and reopening case at bail stage inappropriate where accused bore evidential onus.
18 December 2024
Police fired a rubber bullet at the plaintiff contrary to protocol, rendering the defendant liable for negligent conduct.
Police use of force – rubber bullets – whether plaintiff struck; adherence to dispersal/warning protocol; credibility of witnesses; State liability for wrongful and negligent conduct; costs reserved pending quantum.
5 December 2024
November 2024
Consent order conceding liability may not be rescinded absent court‑attributable patent error, fraud, or justus error; prescription cannot be belatedly introduced.
Consent orders — rescission — Rule 42(1)(b): requires ambiguity or patent error attributable to the court; Justus error/fraud required to set aside consent order; Prescription Act s17(2) — discretion to allow late plea does not permit re‑opening consent judgment where mandate, agreement and finality prevail; finality and prejudice to successful party govern rescission applications.
19 November 2024
Consent orders will not be rescinded for alleged prescription absent court-attributable error or justus error.
Civil procedure – Rule 42(1)(b) – rescission/variation of judgment – requires ambiguity, patent error or omission attributable to the court; cannot be used to reopen consensual settlements. Common law – justus error – rare exceptional remedy; consent orders not set aside absent fraud, mistake attributable to the court, or vitiation of true consent. Prescription – special plea should be raised in pleadings; cannot be introduced to reopen a consent order where it would prejudice plaintiff and undermine finality.
19 November 2024
An exception taken for vagueness without the mandatory Rule 23(1)(a) notice and sufficient particulars is irregular and was dismissed with costs.
Civil procedure – Exception to pleading; Rule 23(1)(a) mandatory notice where pleading alleged vague and embarrassing; Rule 18(4) particulars required in pleadings; Institution of Legal Proceedings Against Certain Organs of State Act 40/2002 – s3(1) notice and special plea; Prescription – proper raising by special plea; matters intertwined with merits may be left for trial.
19 November 2024
Exception dismissed: plaintiff failed to give mandatory Rule 23 notice and did not particularise grounds; special pleas properly raised.
Civil procedure – Exception to pleading – Rule 23(1)(a) mandatory notice and opportunity to remove cause of complaint – Rule 23(3) and Rule 18(4) requirements for clear, concise grounds and particulars – Special pleas (s3(1) Act 40/2002 and prescription) properly raised as matters of law intertwined with merits.
19 November 2024
Applicant failed to establish exceptional circumstances under section 60(11)(a); medical evidence insufficient to justify bail.
Criminal procedure – bail on new facts – section 60(11)(a) CPA – onus on accused to show exceptional circumstances; previous and new facts must be considered together. Evidential issues – cell-phone records and ‘new evidence’ – availability and timing determine whether facts are new. Prisoner health – alleged medical necessity – adequacy of prison healthcare and private consultations at inmate’s expense. Public interest and safety – risk of witness interference, destruction of evidence and endangerment weigh against bail. Separation of powers – court will not usurp prosecutorial discretion to determine charge/schedule in bail proceedings.
12 November 2024
Accused under Schedule 6 failed to establish exceptional new facts (including medical necessity); bail was refused.
Criminal procedure – bail on new facts – section 60(11)(a) CPA – onus on accused to prove exceptional circumstances – new and old facts to be considered together. Pre‑trial detention – medical condition – unsworn specialist letter insufficient to establish exceptional circumstances. Evidence – cell‑phone records and alleged interference – not shown to be new or to undermine State case. Public interest and safety – risk of witness interference and destruction of evidence militates against bail.
12 November 2024
Whether medical issues and cellphone material constitute exceptional circumstances under s60(11)(a) to justify bail.
Criminal procedure — Bail on new facts — section 60(11)(a) CPA — accused bears onus to show exceptional circumstances permitting release. Bail on new facts — repetition and non‑novelty — court must consider totality of old and new facts; same or unmeritorious facts will not succeed. Medical grounds for bail — specialist letter indicating need for regular consultations does not necessarily constitute exceptional circumstances where custodial medical care and referral mechanisms exist. Witness safety and risk of interference — strong countervailing factor against bail in serious, organized offences. Prosecutorial charging discretion and schedule — bail court should not usurp prosecution’s charging decisions; substantive determination of premeditation is for trial.
12 November 2024
October 2024
Applicants had a legitimate expectation and contractual basis for Phase 3; court ordered respondents to file and implement a supervised plan.
Administrative law – learnership/EPWP – three‑phase contractor development programme – legitimate expectation and supervisory relief to compel state to implement outstanding phase; contract and documentary evidence upheld; deregistered entities lack standing; implementation to be effected by state plan subject to procurement/CIDB/Treasury constraints.
15 October 2024
September 2024
Departments occupying leased premises and the Premier had direct, substantial interests and were properly joined to the action.
Civil procedure – Joinder – Direct and substantial interest test for intervention/joinder – application of Mulaudzi and SA Riding for the Disabled Association and Uniform Rule 10. State parties – non-joinder raised by defendant – occupants' proprietary/beneficial interest (furniture/boxes) and budgetary interest of the Premier. Procedural relief – leave to amend particulars, timelines for intention to defend and pleadings. Costs – second and third respondents ordered to pay costs on scale B (rule 69(7)).
3 September 2024
Condonation granted for late answering affidavits to interlocutory Rule 30 and 30A applications; costs reserved.
Civil procedure – Interlocutory applications – rule 6(11) – answering affidavits to be filed within a reasonable time, not automatically the periods in rule 6(5). Condonation – late filing of answering affidavits – delay of 38 days not excessive where respondent failed to set matter down or take steps. Rule 30(2)(c) and rule 30A(2) applications – procedural timeliness and prejudice considered. Rule 37A (case flow management) inapplicable to interlocutory applications to compel or postpone. Costs reserved for determination by the court hearing the substantive amendment application.
3 September 2024
Court granted condonation for late section 3 notice where discovery delays and best interests of minor justified the delay.
Administrative law / civil procedure – Institution of Legal Proceedings Against Certain Organs of State Act 40 of 2002 – condonation for late section 3 notice; requirements of s 3(4)(b): non-prescription, good cause, absence of unreasonable prejudice; discovery delays and need for clinical records as explanatory grounds; best interests of minor claimant; application unopposed.
3 September 2024
Condonation for the minor child’s claim granted; condonation for the mother’s personal claim refused due to delay and non-disclosure.
Institution of Legal Proceedings Against Certain Organs of State Act 40 of 2002 — s3(2) notice — condonation under s3(4). Condonation — requirements: full, detailed and candid explanation; prompt application; assessment of prospects of success and prejudice. Separate treatment of claims — distinction between applicant’s personal claim and minor child’s claim; best interests of the child as upper guardian. Non-disclosure of prior instructions and special power of attorney undermines candour and weighs against condonation. Costs — costs follow result for condonation of minor’s claim (party-and-party, scale B).
3 September 2024
August 2024
Default judgment granted: agreement cancelled and vehicle repossessed; debit-order timing complaint not a defence.
Default judgment – credit agreement – confirmation of cancellation – repossession of secured goods – debtor’s complaint about debit-order timing not a defence – retention of payments – leave to claim deficiency and interest – costs on attorney and client scale.
30 August 2024
Misjoinder upheld as second defendant lacked contractual nexus; 'once-and-for-all' rule inapplicable because causes of action were distinct.
Joinder and misjoinder of defendants — Uniform Rule 10(3); 'once and for all' rule — requirement to consolidate claims from same cause of action; distinction between urgent enforcement relief and subsequent damages claim; principles from Custom Credit v Shembe and recent Constitutional Court authority on causes of action.
27 August 2024
Pre‑trial admissions and expert evidence established that inadequate intrapartum monitoring causally led to the child’s hypoxic ischaemic brain injury; defendant liable.
Medical negligence – obstetric care – inadequate intra‑partum fetal monitoring after Oxytocin augmentation – causal link to hypoxic ischaemic encephalopathy (HIE); Acute‑profound vs partial‑prolonged MRI patterns – ACOG 2019 and peer‑reviewed evidence; Pre‑trial admissions – withdrawal denied; Causation – factual (but‑for) and legal proximity; Punitive costs for abusive defence conduct.
27 August 2024
Respondent’s inadequate monitoring and delayed caesarean caused intrapartum HIE and resultant cerebral palsy; respondent liable.
Medical negligence – obstetric care – inadequate fetal monitoring and delayed caesarean – intrapartum hypoxic ischaemic encephalopathy (HIE) – MRI watershed pattern – causation on balance of probabilities – failure of defendant to call factual witnesses – costs of two counsel.
6 August 2024
July 2024
Proceedings set aside where accused was represented by an attorney practising without a fidelity fund certificate.
Legal Practice Act s84 – fidelity fund certificate mandatory for attorneys practising on own account; Criminal Procedure Act s73(2) – representation permissible only by persons lawfully entitled to appear; practising without fidelity fund certificate is a fundamental irregularity; proceedings vitiated and declared nullity ab initio; remedy: set aside and trial de novo before a different magistrate.
22 July 2024