High Court of South Africa Eastern Cape, Bhisho

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164 judgments
Citation
Judgment date
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
A post‑litigation internal expert report was held privileged and not discoverable; disclosure to an expert who did not rely on it did not waive privilege.
Civil procedure – Uniform Rule 35(3) – discovery – specificity and relevance required in notice and discovery affidavit. Evidence – litigation privilege – documents produced after litigation commenced and for litigation purposes are protected from discovery. Privilege – waiver – furnishing privileged document to third party does not automatically waive privilege unless contents are relied upon or confidentiality is objectively abandoned. Appealability – interlocutory orders may be appealable where interests of justice require (Superior Courts Act s17(1)).
15 June 2023
The respondent is vicariously liable for negligent hospital treatment that caused the applicant's limb amputation.
Medical negligence – failure to detect vascular injury and fracture – failure to refer for angiogram – causation of limb amputation; vicarious liability of health authority; separation of liability and quantum; undisputed expert evidence.
13 June 2023
May 2023
Reported
Rule 35(12) is self‑standing and may be invoked in application proceedings without prior court direction under Rule 35(13).
Rule 35(12) – discovery and production – self‑standing provision applicable to proceedings and applications; does not require prior court direction under Rule 35(13); purposive and contextual interpretation; sanction is negative preclusion separate from Rule 30A striking‑out relief; Rule 35(14) directed to actions and pleading purposes.
30 May 2023
Rescission granted where a default review order was legally incompetent and unenforceable absent a prior entitlement determination.
Administrative law – rescission under Rule 42(1)(a) – order erroneously granted or not legally competent; State Liability Act – service on head of department and State Attorney; Pension law – limits on compelling Pension Fund without prior declaration of entitlement to paid incapacity leave; condonation of late rescission; punitive costs order (attorney and client).
25 May 2023
Amendments that particularise an unlawful arrest/detention claim do not create new, prescribed causes of action.
Civil procedure – special pleas – prescription – where amendments to particulars merely particularise or clarify an existing unlawful arrest/detention claim, they do not constitute new causes of action attracting prescription. Distinction between contumelia (humiliation) and defamation; allegations of humiliation do not automatically plead defamation. Allegations concerning continued detention and causation do not necessarily equate to malicious prosecution.
9 May 2023
April 2023
Applicant granted interim interdict preventing open recruitment for a disputed principal post pending final review.
Education law – school rationalisation and displaced educators – entitlement to placement before open advertising – legitimate expectation and interim interdict; administrative fairness – duty to consult and to follow Personnel Administrative Measures; costs – attorney-and-client scale and possible de bonis propriis against officials.
27 April 2023
Reported
Substandard VBAC monitoring found negligent but plaintiff failed to prove that it caused the neonatal hypoxic‑ischaemic brain injury.
Obstetric/neonatal negligence – VBAC monitoring duty – failure to monitor fetal heart rate breached duty of care; MRI BGT pattern establishes intrapartum hypoxic‑ischaemic insult; causation requirement in medical negligence — inadequacy of unproven maternity‑record entries and inability to infer that proper monitoring would have averted injury; prescription plea dismissed.
25 April 2023
March 2023
Court ordered university to reconsider faculty‑recommended corrected mark and give reasons if it refuses.
Administrative law – judicial review of university governance decisions – PAJA s8(3) – failure to take a critical decision following faculty recommendation – academic marks correction – urgency and condonation of procedural non‑compliance – duty to give adequate reasons.
28 March 2023
February 2023
Public Protector’s reports set aside for jurisdictional overreach, procedural unfairness, reliance on undisclosed intelligence, and inadmissible hearsay.
Public Protector — scope of powers under s 6(4) Public Protector Act — referral to investigative authorities permissible under s 6(4)(c)(ii); jurisdictional limits — may not investigate POCA/PCCA offences beyond incidental referral; natural justice — audi alteram partem requires notice and meaningful opportunity to respond, particularly where FIC material is relied upon; administrative fairness — published report is final; evidence — averments as to decision‑maker's mind tendered by deputies may be inadmissible hearsay and struck out.
14 February 2023
Reported
Court develops common law to allow public‑sector care or pay‑as‑you‑go remedies for medical negligence, assessing public services at a reasonable standard.
Medical negligence — development of common law — public healthcare remedy and undertaking to pay (DZ defences) — evidentiary onus on State pleadings — reasonable standard for public provision — case management, annexe‑based delivery and periodic/private procurement or reimbursement — protection of constitutional rights (s 27, s 28) and public finance considerations.
7 February 2023
Urgent challenge to student election dismissed for non-joinder and inadequate, hearsay-based evidence.
Non-joinder – necessary parties with direct and substantial interest must be joined; urgent interdictory relief – requires clear, admissible evidence and identification of a prima facie right; student governance – compliance with constitution for appointment of IEC/CEO; court may raise non-joinder mero motu to protect third-party interests; vagueness/hearsay in urgent applications is fatal.
3 February 2023
January 2023
Applicant validly terminated a month-to-month lease; respondent’s holding over is unlawful and eviction ordered with 90 days to vacate.
Administrative law — Lease termination and eviction — month-to-month lease — sufficiency of notice; Civil procedure — rule 41A non-compliance; Evidence — disputes of fact on papers and requirement for oral evidence; Property law — holding over; PIE inapplicable to commercial occupation.
31 January 2023
Reported
A life sentence under s51(1) CLAA requires sufficient factual inquiry; inadequate sentencing enquiry warrants remittal for reconsideration.
Criminal law – sentencing – prescribed minimum life sentence under s51(1) CLAA – requirement to identify substantial and compelling circumstances; proportionality principle; duty to elicit sufficient information at sentencing (victim impact assessment, pre‑sentencing report); appellate interference only for material misdirection or disproportionate sentence; remedy: set aside and remit for re-sentencing.
31 January 2023
December 2022
Founding affidavit and unidentified annexures insufficient; new matter in reply inadmissible, application dismissed, each party pays own costs.
Civil procedure – motion proceedings – sufficiency of founding affidavit – applicant must plead and prove case in founding papers; new matter in reply inadmissible; annexures relied upon must be identified; Plascon-Evans test applies to disputes of fact on motion.
14 December 2022
Applicant's motion dismissed for failing to plead and prove its claim in the founding affidavit; new reply material inadmissible.
Motion proceedings – founding affidavit constitutes pleadings and evidence – applicant must make case in founding papers. New matter – replying affidavit cannot introduce new grounds or material except in exceptional circumstances. Documentary evidence – annexures and spreadsheets must be identified; court will not trawl through voluminous documents to find relevance. Hearsay – documents produced for state attorney are hearsay without confirmatory affidavits. Disputes of fact – Plascon-Evans test applies; unresolved disputes preclude final relief.
14 December 2022
Hospital staff negligently managed shoulder dystocia (incorrect positioning and fundal pressure), causing the newborn’s brachial plexus injury.
Medical negligence – Obstetric management – Shoulder dystocia – Failure to apply McRoberts position and suprapubic pressure; use of fundal pressure – Causation of neonatal brachial plexus injury – Liability of state health department.
6 December 2022
Reported
Misdirections on child‑witness competency, adverse comment on silence, and unaddressed inconsistencies required acquittal and release of the appellant.
Criminal law — Sexual offences — Admissibility of child evidence — ss 162 and 164 CPC — court must inquire into competence (distinguish truth/lie) and ability to understand oath or be admonished; evidence inadmissible absent such inquiry. Constitutional rights — Presumption of innocence and right to silence — impermissible to penalise accused for inability to prove a motive or to detail how others were allegedly coached. Evidence — Single‑witness sexual offence — material inconsistencies, delayed reporting and inconsistent first reports must be properly explored; s 58 and s 59 Sexual Offences Act limit but do not eliminate adverse inferences. Appellate review — failure to consider accused’s version and to address material discrepancies constitutes material misdirection requiring acquittal if guilt not proved beyond reasonable doubt.
6 December 2022
Court awarded substantial quantum for a minor’s cerebral palsy injuries, fixing general damages at R2,000,000 and ordering trust funding.
Delict — Medical negligence — Quantum assessment for minor with cerebral palsy — General damages, future loss of earnings, future medical/related expenses and trust funding; Rule 34A interim payment set‑off; refusal of postponement based on pending ‘test case’; allowance of late amendment and reliance on unchallenged expert and actuarial evidence.
2 December 2022
November 2022
Court applied 25% child sliding-scale contingency to future loss of income in RAF claim.
Road Accident Fund – future loss of income – contingency discount – sliding scale application (25% for child) – actuarial quantification – brain injury (diffuse axonal injury) affecting earning capacity.
11 November 2022
Defendant vicariously liable for negligent intrapartum management causing child’s hypoxic brain injury and cerebral palsy.
Medical negligence – obstetric care – failure to monitor labour and act when partogram crossed action line – intrapartum hypoxic ischaemic encephalopathy – causation on balance of probabilities – vicarious liability – extensive costs awarded.
8 November 2022
Appeal against life sentence for rape of two minors dismissed; no substantial and compelling circumstances found.
Criminal law – Sexual offences – Two counts of rape of eight-year-old children – aggravating features include simultaneous assaults in each other’s presence, use of a knife and threats. Sentencing – Minimum sentences (s51 CLAA) – absence of physical injuries does not constitute substantial and compelling circumstances (s51(3)(aA)(ii)). Appeal – sentencing discretion; Malgas test; no material misdirection and sentence not disturbingly inappropriate. Pre-sentence detention and first offender status insufficient on their own to warrant departure from prescribed minimum.
8 November 2022
Reported
Child witness competent; oath/admonishment conflation did not vitiate evidence; conviction upheld with medical corroboration.
Criminal law – Child witness competency and admonishment – s 164(1) Criminal Procedure Act – requirement to establish understanding of nature and import of oath before admonishment; admissibility of child evidence; corroboration by medical evidence; appellate deference to trial credibility findings.
8 November 2022
Appellate court reduced prescribed 15-year sentence to nine years, finding it disturbingly inappropriate given mitigating factors.
Sentencing – minimum sentences for robbery with aggravating circumstances – substantial and compelling circumstances – appellate interference where prescribed sentence is "disturbingly inappropriate"; mitigation: first offender status, minimal violence, value and recovery of property, time spent awaiting trial (COVID-19 context).
8 November 2022
Appellate court upheld convictions and concurrent sentencing for aggravated robbery and possession of a prohibited firearm despite terse trial reasons.
Criminal law – Robbery with aggravating circumstances; possession of a prohibited firearm (serial number removed) – sufficiency of single-witness identification and corroboration by ballistic evidence; appellate review of trial court’s factual findings where reasons were limited. Evidentiary issues – impact of absent forensic tests and of not calling a witness on strength of State case. Sentence – concurrent portion of firearm sentence and appropriateness of overall term.
2 November 2022
Court upheld prescribed minimum sentences for firearm robberies of elderly victims; appeal against sentence dismissed.
Minimum sentences – Firearms Control Act – whether substantial and compelling circumstances exist to depart from prescribed minima; sentencing discretion – misdirection and disturbingly inappropriate test; cumulative effect of concurrent sentences; aggravating factors – prior firearm conviction, victims’ ages, location (home robberies), and injury to victim.
2 November 2022
October 2022
Mandatory order for transfer granted where purchaser proved valid sale and payment despite seller’s bare denials and intestate death.
Property law – sale of immovable property – validity of deed of sale and payment of purchase price; Civil procedure – disputes of fact on motion; Alienation of Land Act 68 of 1981 – formalities and effect; Mandatory interdict – requirements satisfied; Estate administration – intestacy does not prevent compelled transfer; Sheriff authorised to sign transfer documents; punitive costs awarded.
27 October 2022
National Act’s transitional provisions ended the provincial house term; election did not constitute contempt or unlawful conduct.
Traditional leadership — Transitional provisions of Traditional and Khoi‑San Leadership Act 2019 — s63(13) fixes term of provincial houses to 31 May 2022 for houses constituted under prior legislation; national Act prevails where uniformity required (s146(2)(b) Constitution). Interpretation of interlocutory orders — order's protective ambit limited by expiry of office term. Contempt of court — requires wilful and mala fide non‑compliance; honest/mistaken belief in lawfulness negates requisite intent (Fakie NO principle).
27 October 2022
PIE protects evictions from homes only; uncompleted structures are not within PIE’s scope.
Eviction law – PIE Act – scope of application – PIE protects eviction from homes/dwellings only; structures under construction are not 'homes'; evidential onus on occupiers to prove residence or special circumstances; citation of non‑existent respondent does not automatically vitiate proceedings.
14 October 2022
The applicant’s personal and purported executor claims were dismissed for failure to plead or properly represent the deceased child’s estate.
Medical negligence – quantum – separated issues of liability and quantum – effect of death of minor after litis contestatio; Representation and locus standi – executor nomine officio – requirement for formal joinder/substitution and proper pleading for estate claims; Pleadings and trial fairness – inadmissibility/irregularity of late supplementation beyond pleadings causing prejudice; Costs – wasted costs from defective pleadings to be borne by unsuccessful pleader; costs of pre-death expert reports to be determined/ taxed separately.
5 October 2022
September 2022
A substitute educator’s fixed-term contract does not terminate automatically on the incumbent’s death; employer liable for unpaid balance.
Employment law – fixed-term contract for substitute educator; implied term not to terminate on incumbent’s death; statutory framework (Employment of Educators Act; Labour Relations Act) prevails; South African Schools Act – SGB posts must be established and funded to create employer liability; High Court jurisdiction to adjudicate monetary claims arising from fixed-term employment contract.
27 September 2022
Applicant lacked locus standi and failed to prove the respondent was an unlawful occupier; eviction application dismissed with costs.
Property law/PIE – eviction – applicant must be owner or person in charge; executors of deceased estate qualify as owner under PIE and Deeds Registry Act. Locus standi – authority to institute proceedings must be established in founding affidavit; confirmatory affidavits in reply cannot cure lack of locus standi. Unlawful occupation – occupier may have tacit consent/precarium; cancellation must be proved. Procedure – where material disputes of fact exist, action rather than motion proceedings is appropriate; Plascon‑Evans principle governs resolution of factual disputes on motion.
27 September 2022
A promotion/appointment dispute is a labour matter, not administrative action under section 33/PAJA; application dismissed.
Administrative law – Appointment/promotion – Whether failure to recommend/appoint constitutes administrative action under s33/PAJA – Gcaba applied. Labour law – Promotion/unfair labour practice – s185 and s186(2)(a) LRA – promotion disputes are labour matters. Jurisdiction – Pleadings determine forum – High Court lacks jurisdiction where claim is essentially a labour dispute. Procedural – Non-joinder and correct respondent for state employment appointments noted but not determinative here.
27 September 2022
Applicant failed to prove contemnor’s wilful breach; debt satisfied and contempt application dismissed with costs.
Contempt of court — requirements for contempt (order, service/knowledge, non‑compliance); personal service and actual knowledge; contempt inappropriate to compel payment of debt (execution preferable); interest capitalisation (compounding) and application of in duplum rule; overpayment by State satisfied obligation.
27 September 2022
Leave to appeal granted where arguable differences on prescription, identity of debtor, and evidentiary findings existed.
Prescription – section 12(3) – distinction between primary facts and legal conclusion of negligence – Links v Department of Health test; Pleadings – identity of debtor – typographical error did not remove issue from dispute; Evidence – weight of medical witness' testimony and consequences of failure to testify (adverse inference); Deemed/constructive knowledge and its effect on prescription; Costs – reasonableness of two counsel.
14 September 2022
Leave to file a late counterclaim refused for lack of explanation, entitlement and prejudice to the plaintiff.
Rule 24(1) — counterclaim — requirements: reasonable explanation for lateness and entitlement to counterclaim; procedural propriety — written substantive application required (not oral from the bar); litis contestatio — late insertion of new pleadings after trial commencement prejudicial and ordinarily not permitted; prescription and failure to annex claim in reconvention prevent court assessing entitlement.
1 September 2022
August 2022
Court granted condonation and uplifted bar because defendants raised a strong, potentially dispositive defence despite a poor explanation.
Civil procedure – Rule 27(3) – condonation for late filing of plea and upliftment of bar – requirements: full explanation and bona fide defence. Defence – special plea – non-compliance with Institution of Legal Proceedings Against Certain Organs of State Act 40 of 2002. Access to courts – s34 – refusal would unjustifiably infringe constitutional rights. Costs – indulgence granted but costs awarded against applicant where explanation poorly pleaded and no attempt made to obtain consent.
16 August 2022
Court recognised a customary marriage based on ceremony, clan representation, community recognition and tacit waiver of lobolo, dismissing applicants' challenge.
Customary marriage — validity under s3(1) Recognition of Customary Marriages Act — requirements (consent, negotiation/celebration, lobolo, handing over) — flexibility and evolution of customary law — role of clanship and community recognition — registration not essential to validity.
2 August 2022
July 2022
Condonation granted for late statutory notice where expert report crystallised cause of action and respondent showed no unreasonable prejudice.
Administrative law / state litigation – Institution of Legal Proceedings Against Certain Organs of State Act 40 of 2002 – s 3(1)-(2), s 3(4) – notice to organ of state – condonation for late notice. Prescription / delict – when debt becomes due – complete cause of action and requirement of justified true belief; expert report converting suspicion into knowledge. Civil procedure – admission of supplementary affidavit – discretion to allow further affidavits where founding papers inadequate and no real prejudice. Prejudice – respondent must demonstrate unreasonable prejudice from late notice; mere procedural defects do not necessarily defeat condonation.
26 July 2022
Condonation granted for slightly late statutory notice where specialist report triggered claimant’s knowledge and no unreasonable prejudice proved.
Institution of Legal Proceedings Against Certain Organs of State Act 40/2002 – s3 notice requirement; prescription and knowledge – when debt ‘became due’ (specialist report triggers justified belief); condonation under s3(4)(b) – good cause and absence of unreasonable prejudice; admissibility of late supplementary affidavit; service on Department vs Head of Department.
26 July 2022
June 2022
Applicant's claim for loss of income dismissed; retention of lawfully seized vehicle pending criminal proceedings lawful; absolution granted.
Criminal Procedure Act s20 and s35 – lawful seizure and forfeiture of exhibits; Civil jurisdiction pending criminal proceedings; Pure economic loss – requirement to prove all delictual elements including wrongfulness; Absolution from the instance – plaintiff must establish prima facie case on all elements.
13 June 2022
Court upheld appellant’s conviction and life sentence for raping a 10‑year‑old; evidence and sentence found sound.
Rape of a child – single child witness – cautionary rule and evaluation of evidence; medical corroboration of sexual penetration and HIV infection; appraisal of accused’s defence and hearsay; sentencing under s 51(1) Criminal Law Amendment Act – life imprisonment; absence of substantial and compelling circumstances.
10 June 2022
Whether the appellant's personal circumstances amounted to substantial and compelling circumstances to avoid life imprisonment.
Criminal law – Sentencing – Gang-rape attracting prescribed life sentence under s 51(1) of Act 105 of 1997 – Whether personal circumstances amount to substantial and compelling circumstances under s 51(3) – Pre-sentence incarceration insufficient alone to justify deviation – Absence of victim impact assessment not mitigating – Application of Malgas determinative test.
10 June 2022
May 2022
Leave to appeal refused: absence of records, maternity guidelines and expert evidence established probable peripartum hypoxic-ischaemic injury and negligence.
Judicial review of leave to appeal — reasonable prospect of success under s 17(1)(a); medical negligence — evidentiary weight of contemporaneous records and national maternity guidelines as benchmark; expert evidence — joint reports, MRI evidence of peripartum hypoxic-ischaemic injury; repudiation of joint expert report and costs consequences; prescription and pre-action compliance.
31 May 2022
Application for separation refused: common purpose, public interest and prosecution prejudice outweighed alleged delay-based prejudice.
Criminal procedure – Separation of trials under s 157 CPA – Alleged common purpose and POCA-related charges favour joint trial; applicant must demonstrate substantial prejudice from unreasonable delay; discretionary refusal where delays are partly self‑inflicted and prosecution’s interest and public interest outweigh accused’s inconvenience.
10 May 2022
Reported
Precautionary suspension lawful where prima facie misconduct existed and the presence might jeopardise investigation.
Administrative law; employment law – precautionary suspension of senior public official; SMS Handbook para 2.7(2) – prima facie misconduct and reasonable belief presence may jeopardise investigation; urgency for final relief in constitutional/public-interest context; costs against unsuccessful constitutional-style challenge where no genuine constitutional import.
3 May 2022
April 2022
Applicant’s review of Premier’s dismissal of chieftainship claim dismissed for rationality and lack of bias.
Traditional leadership disputes – review under PAJA – rationality review and deference to specialist Commission/Committee fact‑finding; allegations of bias and procedural unfairness; evidential weight of commissioned research and historical documents; Sigcau/Nxumalo distinguished on legislative basis; delays and communication of administrative decisions; Biowatch costs principle.
29 April 2022
Recusal refused: court found inadequate, largely hearsay evidence and that judicial exasperation at delay did not show reasonable apprehension of bias.
Criminal procedure – recusal – reasonable apprehension of bias – test requires an objective, informed reasonable person's view; strong presumption of judicial impartiality. Evidence – inadmissible hearsay about chamber proceedings cannot be used to sustain recusal. Judicial conduct – firm case management and expressions of exasperation at delay do not necessarily amount to bias or trampling presumption of innocence.
28 April 2022
Second marriage held void ab initio as bigamous; Master’s appointment set aside and Letters of Authority cancelled.
Family law — Marriage — Bigamy and nullity — Second marriage void ab initio where earlier marriage subsisted and divorce was pending; Estate administration — Letters of Authority issued to purported spouse invalid; Administrative law — Master’s statutory powers to appoint estate representative preserved; Court will not usurp Master’s functions.
14 April 2022
March 2022
Reported
Court allowed intervention, held state bank accounts may be attached subject to safeguards, and stayed further execution pending appeal.
State Liability Act s3 – enforcement of money judgments against State – movable property includes incorporeal rights; Uniform Rule 45 – requirements for writs and distinction between attachment of incorporeal rights (sale in execution) and garnishee procedure; section 226 Constitution – attachment of departmental bank accounts not per se unconstitutional; stay of execution – discretionary relief to prevent injustice pending appeal.
17 March 2022