High Court of South Africa Eastern Cape, Bhisho

163 judgments
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163 judgments
Citation
Judgment date
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
December 2023
Leave to appeal refused: late postponement and belated defence cannot evade binding compromise; punitive costs upheld.
Civil procedure – leave to appeal – refusal of same-day postponement at commencement of trial; binding effect of parties’ compromise on future medical expenses; late-raised public health care defence cannot negate prior compromise; punitive costs (attorney and client, two counsel) justified for serial bad faith conduct.
12 December 2023
Particulars against the police lacked material facts under Rule 18(4); paragraphs 12–14 set aside and amendment ordered.
Rule 18(4) – Pleadings must set out material facts with sufficient particularity; Rule 30 – irregularity notice and relief; insufficiency of particulars to link police conduct to claimed damages; condonation of slightly premature Rule 30 application; costs follow the event.
5 December 2023
November 2023
A PAIA request filed by the applicant’s attorneys without a power of attorney was valid; non-response deemed refusal and disclosure ordered.
PAIA – access to records – validity of request made by applicant’s attorneys without formal power of attorney – deemed refusal where information officer fails to respond – exhaustion of internal appeal – disclosure of medical and grievance documents under PAIA – court’s discretionary relief under s82.
28 November 2023
Use of K-wire fixation instead of ORIF for an adult intra-articular distal humerus fracture was negligent and caused the plaintiff’s injury.
* Medical negligence – orthopaedic treatment – distal humerus intra-articular fractures – ORIF (open reduction and internal fixation) is standard in adults; percutaneous K-wire fixation is inappropriate for ‘big bone’ adult intra-articular fractures. * Deviation from accepted medical practice without explanation can constitute negligence where harm was foreseeable. * Expert evidence – court must evaluate reasoning; joint minutes binding on agreed facts. * Causation – on balance of probabilities the substandard treatment caused malunion, stiffness and ulnar nerve palsy. * Costs – party-and-party with limitation to one counsel and specific disbursements.
23 November 2023
October 2023
Permanent public-service appointments of non-citizens without statutory qualification are unlawful and were set aside.
Public Service Act s10(1)(a) – prohibition on permanent appointment of non-citizens/non-permanent residents; National policies on employment of foreign health professionals – fixed-term contracts tied to permits; Ultra vires appointments by provincial official – review and setting aside; Public law estoppel inoperative to validate unlawful public appointments; Legality review and state delay – obligations on organs of state and consequences for costs.
10 October 2023
Leave to appeal refused where applicant failed to prove prescription and may not introduce new facts at the leave-to-appeal stage.
Prescription — Prescription Act — defendant bears evidentiary burden to prove date when creditor had requisite knowledge — mere conclusions insufficient; condonation for late statutory notice — court may accept plaintiff's uncontroverted version regarding lack of knowledge and delays by police; functus officio — court will not consider factual averments first raised at leave-to-appeal stage; Mtokonya and Zamani applied.
9 October 2023
Defendant held liable for infant brain damage due to negligent intrapartum monitoring and failure to expedite delivery.
• Medical negligence – intrapartum care – inadequate foetal monitoring, fundal pressure, failure to prepare for emergency caesarean. • Causation – factual (but-for) and legal causation in birth asphyxia cases. • Hospital records – entries by medical staff admissible and may be relied upon by experts. • Expert evidence – radiological and neonatal findings consistent with hypoxic-ischaemic encephalopathy (HIE).
3 October 2023
September 2023
Rule 30A costs on attorney‑client scale awarded for persistent state non‑compliance; removal costs limited to party‑and‑party.
* Civil procedure – case management (rule 37A) and rule 30A – non‑compliance with directives – remedy and costs * Costs – punitive costs (attorney and client) against state party for persistent breach and prejudice * Removal from roll (rule 41(1)(a)/(c)) – removal versus withdrawal; removal without tender attracts costs (party‑and‑party) * Rule 36(9) / expert evidence – obligation to file expert notices and reports; prejudice from delayed expert production * Condonation – late supplementary/replying affidavits granted (unopposed)
19 September 2023
Defendant failed to prove respondent had requisite knowledge to start prescription; appeal dismissed with costs.
Prescription – Prescription Act s 12(1) and (3) – medical negligence – knowledge of material facts (facta) versus legal conclusions – deemed knowledge by exercising reasonable care – reduced evidential burden where facts peculiarly within opponent’s knowledge – requirement of prima facie probative evidence before adverse inference for non‑testifying party.
15 September 2023
Filing a notice of appeal suspends execution; magistrate’s execution-pending-appeal order is a nullity; relief granted urgently.
Administrative law; appeal suspends execution of judgment; magistrate has no power to order execution pending appeal (nullity); urgency—rule 6(12); jurisdiction to grant interlocutory relief ancillary to appeals; restraint on creditor instructing bank to maintain debit holds during appeal.
14 September 2023
Reported
Conviction for contravening a protection order set aside for insufficient evidence and for improperly imposing an onus on the accused.
Domestic Violence Act — contravention of protection order (s 17(1)(a)) — sufficiency of evidence; criminal onus — impermissible requirement that accused explain why complainant might lie; conviction set aside for failure to prove charged particulars (insult by reference to private parts and chasing).
7 September 2023
August 2023
Leave to appeal granted where factual causation for birth-related hypoxic-ischaemic brain injury may be reconsidered on appeal.
* Medical negligence – obstetric care – alleged failure to monitor foetus during labour – causation in hypoxic-ischaemic brain injury (BGT pattern). * Expert evidence – MRI interpretation and timing/etiology of brain injury – inability to establish when injury occurred. * Comparative authorities – relevance of Professor Smith’s study and the SCA decision in DM to factual causation. * Leave to appeal – granted where reasonable prospect exists that appellate court may reach different conclusion on causation.
30 August 2023
Final winding-up orders confirmed: respondents commercially insolvent; proposed sales, valuations and Covid-19 defence insufficient to avoid liquidation.
Companies — liquidation — confirmation of provisional winding-up order — standard of proof higher for final order; commercial (liquidity) insolvency vs factual (asset/liability) insolvency; alleged rescue transactions and outdated valuations insufficient to avoid liquidation; Covid-19 lockdown not a valid supervening excuse where insolvency pre-existed and persisted.
17 August 2023
Threats, conduct and credible eyewitness evidence established premeditated murder; appeal and challenge to life sentence dismissed.
Criminal law – Murder and attempted murder – Eyewitness credibility – Threats and prior conduct – Premeditation and mandatory life sentence (s51(1) CLAA) – No substantial and compelling circumstances to deviate from life imprisonment.
17 August 2023
Applicant’s psychiatric injury claim failed for lack of psychiatric expert evidence; leave to appeal refused.
Medical negligence – claim for psychiatric injury – requirement that a recognisable psychiatric lesion be proved ordinarily by psychiatric/psychological expert evidence; lay testimony insufficient; obstetric/paediatric evidence cannot substitute for psychiatric expertise; leave to appeal requires reasonable prospect of success.
15 August 2023
A genuine constitutional challenge to a university expulsion attracted the Biowatch rule; each party ordered to pay its own costs.
University disciplinary review – right to further education (s29) and review of administrative action (s33/principle of legality) – Biowatch costs rule applies to genuine constitutional challenges against organs of state – exceptions (frivolous/vexatious or conduct deserving censure) not found – interim relief permitting continued online study; each party to pay own costs.
8 August 2023
8 August 2023
Detention under an invalid post-appearance warrant violated s12(1)(a); Minister of Police held liable and R400,000 awarded.
Criminal procedure – detention after court appearance – validity of detention warrant (J7) – warrant must be based on court order – mere production of warrant prima facie lawful but not conclusive – right to freedom s12(1)(a) – state liability for unlawful detention – assessment of damages for unlawful detention (39 days).
8 August 2023
Applicant’s late challenge to refusal of penalty‑free early retirement dismissed for undue delay and weak merits.
Administrative law – review – undue delay and condonation – review applications must be brought without undue delay; courts may refuse to condone lengthy unexplained delay where finality and prejudice to administration arise; Public Service Act s 16(6) – early retirement discretion – DPSA/NT circulars and guidelines make penalty‑free early retirement subject to funding and departmental criteria; acquiescence and receipt of benefits undermine later review.
8 August 2023
Appellants’ convictions and prescribed sentences for robbery and murder upheld; common purpose and dolus eventualis established.
Criminal law – murder and robbery – doctrine of common purpose – liability by active association; dolus eventualis established by multiple stab wounds; appellate review of factual findings; sentencing – prescribed minimum sentences and absence of compelling and substantial circumstances to deviate.
8 August 2023
July 2023
The applicant’s child suffered HIE and cerebral palsy from negligent intrapartum and neonatal care; respondent held liable.
Obstetric/neonatal negligence – inadequate partogram and CTG monitoring; failure to act on pathological CTG and probable inappropriate oxytocin augmentation; intrapartum hypoxic-ischaemic encephalopathy causation established on balance of probabilities; genetic causes considered but not determinative.
27 July 2023
Appeal succeeds: inadequate intrapartum monitoring caused a preventable hypoxic brain injury; expert joint minutes and missing records decisive.
Medical negligence — intrapartum care — adequacy of foetal monitoring; Expert evidence — joint minutes between experts binding absent timeous repudiation; Missing clinical records — adverse inference where custodian fails to explain non‑production; Evaluation of single witness evidence against objective records; Causation — intrapartum partial‑prolonged hypoxic ischemic insult consistent with MRI and expert opinion.
20 July 2023
Applicant failed to prove ownership; municipality’s transfer was lawful and the application was dismissed with costs.
Property law – ownership and transfer – Alienation of Land Act formalities; administrative transfer by municipality; evidentiary weight of title deeds and Registrar of Deeds report; condonation of late replying affidavit; commissioning/attestation of affidavits – directory non‑compliance and substantial compliance; costs and inapplicability of Biowatch where applicant not candid.
20 July 2023
Condonation granted where organ of state’s delay in providing the docket prevented timely statutory notice, and no prejudice shown.
Institution Act s3(2) & s4(b) — condonation of late statutory notice; Prescription Act — when debt becomes due; knowledge of identity and facts; organ of state wilful prevention of knowledge; requirement of no unreasonable prejudice and good cause.
18 July 2023
June 2023
Applicant obtained interim interdict preventing SIU investigating his Master’s registration, as Proclamation was limited to Honours.
• Administrative law — SIU Proclamation — scope and interpretation of Proclamation Schedule — expressio unius exclusion alterius; • SIU Act — ultra vires investigation where scope not authorised by Proclamation; • Interim interdict — requirements (prima facie right, irreparable harm, balance of convenience) — investigatory steps restrained pending review; • Urgency and separation of powers considered; • Rights engaged: privacy, dignity and lawful investigative process.
20 June 2023
Reinstatement requires the employee to report for duty; arrears are payable only after the contract is revived.
Employment law – reinstatement – court order reinstating employee does not revive contract until employee physically reports and tenders services; arrear pay not payable prior to tender of services; consent order requiring assumption‑of‑duty forms must be complied with; refusal to report cannot be condoned to revive employment; relief to enforce arrears inappropriate where employee prevents implementation.
20 June 2023