High Court of South Africa Eastern Cape, Bhisho - 2024

43 judgments
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43 judgments
Citation
Judgment date
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Consent order conceding liability may not be rescinded absent court‑attributable patent error, fraud, or justus error; prescription cannot be belatedly introduced.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Consent orders will not be rescinded for alleged prescription absent court-attributable error or justus error.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
Failure to monitor fetal heart rate per guidelines during labour caused intrapartum HIE; defendant held liable and ordered to pay costs.
Obstetric/neonatal negligence – inadequate fetal heart‑rate monitoring contrary to Maternity Guidelines – intrapartum hypoxic ischaemic encephalopathy causation; weight of pre‑trial admissions and joint expert minutes; rejection of speculative genetic/antenatal alternatives.
19 July 2024
Life sentence for repeated rape of a mentally vulnerable child by a father‑figure was not disproportionate; no substantial and compelling mitigation.
Criminal law – Minimum sentences – Rape of a child under 16 – Substantial and compelling circumstances; proportionality of prescribed life sentence; abuse of position of trust; effect of complainant's cognitive impairment; intoxication as mitigation.
16 July 2024
Life sentence for repeated rape of a vulnerable child by a father-figure was proportionate; appeal against sentence dismissed.
Minimum sentencing – rape of a child under 16 – substantial and compelling circumstances – abuse of position of trust; victim vulnerability (young age, cognitive impairment); repeated penetrative assaults; intoxication not established as mitigating; appellate reassessment of substantial and compelling circumstances permitted.
16 July 2024
A magistrate may not stay eviction proceedings absent a filed counterclaim in reconvention showing a prima facie prospect of success.
Civil procedure – Magistrates’ Court Act s47(1) – counterclaim/claim in reconvention exceeding jurisdiction – requirement to file reconventional claim before stay may be granted. Civil procedure – Rule 20 – procedure to apply for stay where claim in reconvention exceeds jurisdiction. Eviction law – stay of eviction pending High Court review to set aside transfer – Magistrates’ Court lacks jurisdiction to set aside transfer; stay only permitted upon filing of reconventional claim demonstrating prima facie prospect of success. Costs – appellate interference where lower court misdirected on costs though substantive decision stands.
9 July 2024
June 2024
The defendant held vicariously liable for unlawful closure, assault and arrest of the applicant by SAPS members.
Police liability; unlawful closure of licensed premises; unlawful assault and arrest; J534 written notice; occurrence register as evidentiary admission; vicarious liability of State for SAPS conduct.
28 June 2024
Police unlawfully closed a tavern and unlawfully assaulted and arrested its proprietor; state held vicariously liable.
Police powers – unlawful closure of business premises; timing and justification of closure. Assault and arrest – evidentiary weight of J88 medical report and occurrence register entries. Written notice (J534) – procedural defects and failure to comply with s56 Criminal Procedure Act requirements. Vicarious liability – Minister of Police liable for wrongful acts of police members.
28 June 2024
Arrest and detention lawful on reasonable suspicion; malicious prosecution not proven; plaintiffs' claims dismissed with costs.
Criminal procedure – warrantless arrest under s 40(1)(b) CPA – reasonable suspicion based on injured person, blood and weapons; discretionary arrest and detention pending bail; malicious prosecution – requirement of reasonable and probable cause and animus injuriandi; prosecutor’s decision-making and objective reasonableness.
20 June 2024
Failure to monitor a high‑risk labour led to intrapartum hypoxic brain injury; the defendant held vicariously liable for full damages.
Medical negligence — Obstetric nursing care — Failure to monitor fetal condition in high‑risk labour — Missed signs of fetal distress and meconium aspiration — Partial prolonged hypoxic‑ischaemic brain injury — Causation on balance of probabilities — Vicarious liability of State — Costs and interest awarded.
11 June 2024
Accused of Schedule 6 offences discharged exceptional-circumstances onus; appeal court granted bail with conditions.
Criminal procedure – Bail – Schedule 6 offences – Onus on accused to prove exceptional circumstances (s60(11)(a)) – Court must weigh s60(4) likelihoods against s60(9) factors – Magistrate’s misdirection and speculative findings may justify appellate interference under s65(4) – Granting bail subject to restrictive conditions.
7 June 2024
Magistrate properly refused bail for Schedule 6 offences; appellants failed to prove exceptional circumstances given violence and flight risk.
Criminal procedure – Bail – Schedule 6 offences – onus on accused to prove exceptional circumstances under s 60(11) CPA – ordinary personal circumstances not ordinarily exceptional. Bail – factors: violence, police pursuit, possession of firearms and stolen property, attempts to evade arrest amounting to danger and flight risk. Appeal – review of magistrate’s discretion – intervention only for material misdirection of fact or law; none established.
6 June 2024
May 2024
A department cannot pay a consent-ordered award in instalments absent an agreement with the accounting officer.
Pre-trial and experts' joint minutes binding; public health defence exclusion; State Liability Amendment Act and PFMA require payment within 30 days absent agreement; consent-order variation not permitted without proper application.
27 May 2024
A fairness-based approach awarded sole authority over burial to the surviving spouse despite periods of separation.
Burial disputes – competing claims between surviving spouse and child; fairness approach to burial authority; whether separation equals paper marriage; evidentiary weight of alleged dying wishes; urgent relief where body held in mortuary.
18 May 2024
Plaintiff’s personal claim had not prescribed and statutory notice requirement was not shown to be breached; both special pleas dismissed.
Prescription – three-year period (s11(d) Prescription Act) – knowledge requirement (s12(3)) – onus on party alleging prescription to prove date of knowledge; Institution of Legal Proceedings Against Certain Organs of State Act 40 of 2002 – s3(1)(a) statutory notice – purpose to prevent prejudice and allow investigation – failure to prove prejudice; uncontroverted concession by State witness fatal to special pleas.
7 May 2024
April 2024
The plaintiff failed to prove unlawful arrest, unlawful continued detention, or malicious prosecution by the State.
Criminal procedure – Arrest without warrant – s40(1)(b) CPA – objective test of reasonable suspicion; Exercise of arrest discretion; Bail procedure – Schedule 6 offences and onus to show exceptional circumstances; Unlawful detention – causation and necessity of specific pleaded facts; Malicious prosecution – reasonable and probable cause and animus injuriandi; Pleading standards in actions for unlawful arrest and detention.
26 April 2024
Ex parte removal by a non-designated social worker was unlawful; court restored parental rights with supervised medical transition.
Children’s Act and parental rights – ex parte removal – locus standi of private medical social worker – Rule 57 compliance – curatrix personae – best interests of child with disabilities – joinder of Trust – supervised transitional placement and training.
25 April 2024
Application for rescission of 2011 striking‑out order and 2015 default judgment dismissed for deliberate default, delay and public‑interest finality.
Rescission — Uniform Rule 42(1)(a) — requirement of being ‘absent’ in legal sense; erroneous grant — Rule 35(7) two‑stage discovery/striking‑out procedure; common‑law rescission — dual test of satisfactory explanation and bona fide prospects of success; acquiescence, delay and finality of litigation; costs on attorney‑and‑client scale including two counsel.
25 April 2024
Advanced age alone does not justify departing from life sentence for calculated rape of a foster child.
Criminal law – Minimum sentencing – Rape of a minor in care – Prescribed life sentence; advanced age alone is not necessarily substantial and compelling; breach of trust, repeated and calculated abuse and severe psychological harm are significant aggravating factors; appellate interference with sentencing limited to misdirection or startling inappropriateness.
16 April 2024
Reported
Placental pathology indicated antepartum injury from chorioamnionitis, not proven intrapartum negligence; appeal dismissed.
Medical negligence – causation – importance of placental histopathology and arterial blood gas in timing hypoxic-ischaemic injury; expert evidence – weight and fact-based reasoning; admissibility and effect of undisputed medical records; limitations of CTG monitoring; appeal standard on factual findings.
9 April 2024
Withdrawal of a defendant’s special plea is not a “proceeding” under Rule 41(1), so Rule 41(1)(c) costs relief is unavailable.
Uniform Rule 41(1)(a),(c) – meaning of “proceedings” – ‘geding’ (action/application) – withdrawal of special plea not a withdrawal of proceedings – special plea is a defensive pleading; costs – Rule 41(1)(c) remedy unavailable where special plea withdrawn.
8 April 2024
March 2024
Applicant entitled to return of lawfully seized firearm, licence and cartridges after unreasonable retention and inadequate State justification.
Criminal procedure — Seizure and detention of articles (ss 20–31 Criminal Procedure Act) — Two-stage enquiry under s31 — applicant must prove no pending or reasonably likely criminal proceedings; onus then shifts to State to prove applicant not lawfully entitled to possession — detention must be reasonable and not oppressive — inadequate, hearsay answering affidavit by deponent without personal knowledge insufficient to resist return.
27 March 2024
District hospital’s failure to provide timely caesarean or transfer breached guidelines and caused newborn’s hypoxic brain injury.
Medical negligence – Obstetric care – Failure to ensure district hospital able to perform emergency caesarean 24/7 – One‑hour decision‑to‑delivery rule – Causation of intrapartum hypoxic ischaemic brain injury leading to cerebral palsy – Liability and costs.
19 March 2024
Negligent intrapartum management, inadequate monitoring and delays in intervention caused a neonatal hypoxic‑ischaemic injury leading to cerebral palsy.
Medical negligence – obstetric care – prolonged labour, untreated gestational hypertension, inadequate CTG monitoring and delayed delivery; Radiology – MRI pattern consistent with peri‑partum hypoxic‑ischaemic injury (PBGT/Central); Causation – application of Consensus/ACOG criteria and balance of probabilities to link negligent intrapartum management to neonatal encephalopathy and subsequent cerebral palsy; Poor record‑keeping as evidence of substandard care.
15 March 2024
February 2024
Applicant church failed to establish a clear right or imminent harm; interdict refused and no costs ordered.
• Civil procedure – locus standi in motion proceedings – deponent to affidavit versus authority to institute and prosecute proceedings. • Interdict – requirements: clear right, reasonable apprehension of harm, absence of adequate alternative remedy (Plascon‑Evans application). • Church/internal governance – scope and relevance of internal dispute-resolution clause to court proceedings. • Membership evidence – pledge cards as proof of entitlement to worship and use of church premises. • Costs – discretion to depart from usual rule where dispute is between individuals within same juristic entity.
6 February 2024
January 2024
Default PAIA order rescinded where requester failed to comply with PAIA formalities and misstated material facts to the court.
Administrative law – Promotion of Access to Information Act (PAIA) – mandatory compliance with procedural requirements and prescribed forms for requests and internal appeals; court may not order disclosure absent full compliance. Civil procedure – rescission under Rule 42(1)(a) – an order is ‘erroneously granted’ where material facts unknown to the court, if disclosed, would have prevented the order; duty of disclosure in default/ex parte proceedings. PAIA procedure – applications must be addressed to the information officer (or head); improper citation of Minister of Police may render orders erroneous.
30 January 2024