High Court of South Africa Eastern Cape, East London Local Court - 2023

47 judgments
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47 judgments
Citation
Judgment date
December 2023
Reported
Provisional sequestration refused where applicants failed to prove debt, insolvency or trust-account shortfall to establish directors' liability.
Company law – section 19(3) Companies Act – directors of personal liability companies personally liable for contractual debts contracted during period of office; Company law/insolvency – provisional sequestration under Insolvency Act sections 9 and 10 – creditor must prove debt, shortfall and factual insolvency; Evidence – necessity to prove trust-account shortfall by affidavit, not hearsay; Mandate law – theft of damages awards may give rise to contractual claim (breach of mandate) but must be proved.
5 December 2023
November 2023
Court permits substitution of a misdescribed defendant with a company where amendment is bona fide and causes no incurable prejudice.
Civil procedure – Amendment of pleadings – Uniform Rule 28 permits substitution/correction of misdescribed parties where amendment is bona fide, causes no incurable prejudice and preserves continuity of the claim; Rule 30 irregular proceedings – court may set aside or allow amendment; service on representative/director can suffice as notice.
30 November 2023
Discharge under s174 granted where medical expert evidence was unqualified and the child complainant’s testimony was unreliable.
Criminal procedure – s174 discharge at close of State case; admissibility of expert medical evidence – qualification and experience of forensic nurse; evaluation of single child complainant’s credibility, capacity and trustworthiness; distinction between consistency and corroboration in sexual offence prosecutions; State’s duty to present technically proficient evidence.
17 November 2023
Urgent enforcement of a CFO appointment dismissed: no enforceable contract, lack of urgency, and justified investigation into alleged misrepresentation.
Employment law — jurisdiction and interplay with the LRA; Urgency — requirements for urgent relief; Contract formation — letter of appointment as preliminary offer and counter-offer consequences; Non-disclosure/misrepresentation — impact on senior-manager appointment; MEC supervisory powers (s56(6) Systems Act) and separation of powers harm; Interim interdict — Plascon-Evans standard and balance of convenience.
9 November 2023
October 2023
Receipt of an inheritance does not automatically relieve interim spousal maintenance; non-disclosure may attract cost penalties.
* Family law – Rule 43(6) – interim maintenance pendente lite – purpose to preserve status quo ante – inheritance receipt does not automatically extinguish spousal maintenance obligation. * Civil procedure – Rule 43(6) variation – material non-disclosure may attract sanctions or variation of urgent relief granted. * Costs – non-disclosure may lead to forfeiture or reduction of costs awards; courts may set aside urgent payments granted on misapprehension of financial position.
31 October 2023
A post‑commencement lender can have standing to challenge business rescue, but non‑joinder and inadequate service of creditors defeat immediate relief.
Business rescue — standing of post‑commencement lender as creditor; joinder and adequate service of creditors and affected persons; electronic service by Sheriff authorised with prescribed safeguards; urgency and fair hearing obligations of business rescue practitioner.
24 October 2023
The plaintiff’s mild head injury deemed to cause lifelong unemployability; substantial loss of earnings awarded.
Road Accident Fund — proof and quantification of past and future loss of earnings; mild traumatic brain injury — persistent cognitive and psychological sequelae causing unemployability; actuarial computation of capitalised loss; court’s discretion on contingency deductions (5% past, 25% future); RAF statutory cap inapplicable where capitalised loss falls below cap.
10 October 2023
September 2023
Reported
Court granted urgent PAIA disclosure but refused to truncate PAJA’s 90‑day period; each party to pay own costs.
Access to information – PAIA: requester complied with procedural requirements; deemed refusal after 30 days; court may compel production under s82. Administrative justice – PAJA: request for reasons under s5; court declined to reduce 90-day period under s9(1). Urgency and condonation: non-compliance condoned where implementation of award risks prejudice. Third‑party records: possible s47 notification but not fatal to relief.
19 September 2023
The court condoned non-compliance with procedural rules and ordered release of tender documents, though not reducing PAJA timeline.
Administrative law – Urgent applications – Promotion of Administrative Justice Act – Reasons for tender award – Promotion of Access to Information Act – Right to access records.
19 September 2023
Court compels the Minister to decide the applicant’s outstanding internal review under the Immigration Act within a reasonable period.
* Immigration law – Internal review/appeal under section 8 of the Immigration Act – Minister as appropriate decision-maker for internal appeals. * Administrative law – duty to consider and decide internal appeals within a reasonable period where statute is silent on time-limits. * Procedural relief – mandamus to compel consideration of an internal review; PAJA inapplicable to bar such relief where decision not yet made.
15 September 2023
Referral to oral evidence dismissed; court orders expert supplementation of Family Advocate report and mediation to determine child's best interests.
Family law – Child relocation – Rule 6(5)(g) – referral to oral evidence requires a material bona fide dispute of fact – evaluative critique of Family Advocate’s report does not necessarily create such disputes – court may order supplementation under s29(5) Children’s Act – appointment and remit of independent expert; mediation under rule 41A.
15 September 2023
Violent, repeated, weapon‑facilitated rapes did not constitute substantial and compelling circumstances to avoid prescribed life sentences.
* Criminal law – Sentencing – prescribed minimum sentences – applicability of life imprisonment for rape where victim under 16, repeated rapes, or rape by more than one person acting in furtherance of a common purpose. * Sentencing – substantial and compelling circumstances – personal mitigation (first offender, youth) insufficient where offences are violent, repeated and weapon‑facilitated. * Ancillary orders – inclusion on National Register for Sex Offenders, placement on National Child Protection Register, firearm disqualification.
15 September 2023
A close corporation’s claim against a member for misappropriation is not defeated by attributing a surviving member’s knowledge to the corporation.
Close corporations – misappropriation by member – Prescription (s12(3) Prescription Act) – constructive knowledge – attribution of member’s knowledge to corporation – Meridian; Jetivia – where company sues its fiduciary, attribution to defeat claim inappropriate – survivor entitled to withhold insurance proceeds under contractual clause to satisfy corporation’s debt.
14 September 2023
Unsigned founding affidavit and premature litigation led to dismissal of mandamus application with costs.
Administrative law — mandamus relief against municipality — unsigned founding affidavit fatal to proceedings; rectification without condonation insufficient — locus standi and prematurity; requirement to afford state agency reasonable opportunity to investigate; costs awarded against opportunistic litigant.
12 September 2023
Interim relief granted to secure seized documents pending review of the validity of search warrants and privacy complaints.
Search and seizure — Validity of search warrants (Cybercrimes Act and Criminal Procedure Act) — Jurisdictional requirements: reasonable suspicion and reasonable grounds that objects connected with offences are at premises — Overbreadth and privacy infringement — Interim relief to secure seized items pending review.
12 September 2023
August 2023
Court convicted accused of multiple rapes after accepting complainants’ testimony, medical evidence and corroboration, rejecting defence versions.
Sexual offences — rape — evaluation of single‑witness testimony with caution; corroboration by J88 medical reports and contemporaneous conduct; identification evidence — reliability despite no parade; use of weapons (knife/sjambok) as corroborating factor; robbery with aggravating circumstances not established where knife used by co‑perpetrator.
29 August 2023
Mortgagee entitled to execution; sale of respondent’s primary residence suspended until 1 November 2023 with reserve price.
* Mortgage bond – Uniform Rule 46A application to declare property specially executable – bank’s entitlement to execute on mortgage security – court’s discretion to suspend execution. * Primary residence – consideration of debtor’s personal circumstances, income sources, and prospects to remedy arrears. * Sale in execution – fixation of reserve price and provision for subsequent sale without reserve. * Costs – attorney-and-client scale ordered against respondent.
17 August 2023
Rule 30 cannot be used to challenge substantive compliance with Rule 32(2)(b); such disputes belong in the summary judgment hearing.
Civil procedure — Summary judgment — Uniform Rule 32(2)(b) — affidavit must verify cause of action, identify points of law, state facts relied upon and briefly explain why defence raises no triable issue — substantive requirements. Civil procedure — Rule 30 — intended for irregularities of form; not appropriate to challenge substantive compliance with Rule 32(2)(b). Summary judgment — objections to supporting affidavits to be raised in summary judgment proceedings (strike out/ignore), not by separate Rule 30 application. Costs awarded, including costs of two counsel.
8 August 2023
Applicants failed to establish urgency or illegality of municipality's 80/20 prepaid electricity debt-collection policy.
Municipal law – Credit control and debt-collection policy – Lawful implementation of partial restriction (80/20) on prepaid electricity; urgency and interim interdict requirements; tenant standing and evidentiary burden; publication and council adoption of municipal policy; separation of powers and municipal duty to collect revenue.
1 August 2023
July 2023
The applicant improperly sought striking out under Rule 23(2) instead of pursuing Rule 30 for pleading irregularity.
Civil procedure – interlocutory applications; Rule 23(2) strike‑out – court confined to pleadings; Rule 6(11) – affidavits not always required; Pleadings – Rule 18(6) obligations to identify and annex contracts; Irregularity of form to be addressed under Rule 30/Rule 18(12), not by Rule 23(2).
27 July 2023
Reported
A municipality may adopt an 80/20 debt collection policy, but must give a 14‑day written notice before restricting pre‑paid electricity purchases.
Municipal law – Credit control and debt collection policy – validity of council‑adopted Credit Control Policy; Pre‑paid electricity – 80/20 allocation of purchases to arrears; Administrative law – procedural fairness/PAJA – 14‑day written notice required prior to implementing debt‑collection measures; Urgent procedure – Rule 6(12) – and costs consequences for non‑compliant affidavits.
25 July 2023
Municipality failed to comply with order to reconnect electricity; conduct found vexatious and costs awarded.
Municipal law — electricity supply — non-compliance with court order to reconnect supply — alleged electrical fault vs. disconnection for arrears — 80/20 deduction policy — abuse of court process — costs awarded.
25 July 2023
An urgent Rule 45A application to suspend execution of a default judgment pending rescission was granted and condonation permitted.
* Civil procedure — Urgent application and condonation — Rule 6(12) — Self-created urgency principle. * Civil procedure — Interim relief suspending execution — Rule 45A — Suspension of operation/execution of default judgment pending rescission. * Default judgment — Effect on third-party enforcement and risk of contempt proceedings. * Procedure — Adjudication on applicant's papers where respondent files no answering affidavit. * Costs — Costs awarded against respondent for opposing interim relief.
21 July 2023
Court ordered pendente lite custody, maintenance and R35,000 attorneys' fee payment, leaving application costs to the divorce action.
Family law – Rule 43 pendente lite relief – child residence, contact and maintenance – costs: contribution to applicant's attorneys from sale proceeds; discretion under s10 Divorce Act; usual practice to make application costs costs in the divorce action.
20 July 2023
Arrest and detention were lawful where police had objectively reasonable suspicion and properly exercised their discretion; plaintiff's claims dismissed.
* Criminal Procedure Act s40(1)(b) – arrest without warrant – requirement of reasonable suspicion based on credible, specific information. * Jurisdictional facts – peace officer, reasonable suspicion, Schedule 1 offence. * Reasonable suspicion – objective test; corroboration and verification of information required. * Discretion to arrest – must be exercised rationally, in good faith and not arbitrarily; police standing orders relevance. * Detention lawfulness – arrest and detention distinct; detention lawful if charged promptly and brought to court; subsequent withdrawal of prosecution does not automatically render prior detention unlawful.
18 July 2023
June 2023
Municipal rates policy adopted without meaningful public participation was declared unconstitutional and invalid; social housing classification criticised.
Administrative law — Legality review of municipal legislative action — Municipal budget and rates policy — Requirement for meaningful public participation under Systems Act, MFMA and Rates Act — Social Housing Act obligations — Classification of social housing institutions for rates and discretionary rebates — Relief and remedial discretion under s 172 of the Constitution.
26 June 2023
Leave to appeal against an interlocutory postponement and costs order dismissed; condonation refused and order correction upheld.
* Civil procedure – leave to appeal – interlocutory order postponing trial and costs – leave refused where appeal lacks reasonable prospects or practical effect. * Condonation – delay in filing leave application – unsatisfactory explanation and prejudice considerations. * Uniform Rules of Court, Rule 42(1)(b) – correction of patent omission or ambiguity in court order permissible. * Superior Courts Act – consideration of whether appeal would have practical effect. * Professional conduct – referral of transcript to Legal Practice Council for indecorous conduct in court.
20 June 2023
Summary judgment refused where municipal defendant raised bona fide defences including prescription and failure to give Institution Act notice.
* Summary judgment – lease arrears – bona fide defences – ledger entries and invoices disputed – triable issues. * Prescription – interruption by acknowledgement; factual inquiry requiring trial. * Institution of Legal Proceedings against Certain Organs of State Act 40 of 2002 – notice requirements may bar claim; condonation inappropriate in summary judgment. * Allocation of payments (clause 4.2) – material and should have been pleaded. * Interest – necessity of demand and proper pleading/particularisation.
13 June 2023
The insured driver's inopportune right-hand turn across the plaintiff's line of travel was sole cause of the collision.
* Delict – Road traffic collision – negligence – inopportune right-hand turn across right of way – sole cause of collision. * Evidence – assessment of credibility and probabilities – corroboration by independent witness and photographic/scene evidence. * Costs – award of costs to successful plaintiff including costs of two counsel and reasonable inspection/photograph costs.
8 June 2023
An appeal under s12A of the PPA does not, on the statutory text, rebut the common-law presumption that lodging an appeal suspends an administrative licence decision.
Administrative law – Appeal under statute – Whether lodging appeal under s12A of PPA suspends administrative licence decision – Presumption of automatic suspension of administrative decisions pending appeal – Statutory text as determinant of whether presumption is rebutted – Leave to appeal under s17(1)(a) Superior Courts Act requires reasonable prospects or compelling reason.
6 June 2023
May 2023
Respondent’s staff were negligent in monitoring, but applicant failed to prove that negligence caused the neonatal brain injury; claim dismissed.
Medical negligence – intrapartum fetal monitoring – failure to monitor despite multiple vaginal examinations; Missing medical records – evidentiary consequences and shifted evidentiary burden; Expert joint minute (MRI) – basal ganglia–thalamic peri/intrapartum injury; Causation – necessity to prove negligence caused neonatal HIE; Costs discretion – refusal to order costs against applicant given severe lifelong disability of child.
9 May 2023
Warrantless arrest and subsequent detention/prosecution were justified; malicious prosecution claim failed; plaintiff’s claims dismissed.
Criminal procedure — warrantless arrest under s 40(1)(b) CPA — reasonable suspicion based on victim statements and J88; detention after first appearance — Schedule 6 offences and s 60(11)(a); malicious prosecution — requirement of reasonable and probable cause and animus (dolus eventualis); acquittal not determinative of malice.
6 May 2023
Where merits were settled, the court found the respondent’s settlement pragmatic, non‑concessory, and ordered each party to pay own costs.
Administrative law – review of investigating committee decision; costs – discretionary award where merits settled; settlement proposals not necessarily concessions on merits; non‑joinder – necessity to join provincial council, investigating committee and practitioner with direct and substantial interest; Legal Practice Act – role of provincial council and investigating committees; procedural compliance – alleged failure to deliver committee record (rule 53).
4 May 2023
Applicant allowed to correct defendant's misnomer; amendment granted and respondent ordered to pay attorney-and-client costs.
Civil procedure – amendment of pleadings – correction of misnomer vs substitution of a new party – leave to amend allowed where identity discernible from pleadings and annexures; prejudice required to resist amendment. Costs – punitive attorney-and-client costs for obstructive conduct.
4 May 2023
April 2023
Debt underpinning occupier’s claimed retention right prescribed; eviction under PIE granted as just and equitable.
Eviction under PIE – occupier’s claimed lien/pledge over immovable property – prescription of underlying debt extinguishing contractual retention right – res judicata/issue estoppel inapplicable where prior judgment did not decide the occupier issue – rule 46A does not prevent private sale once property declared executable.
25 April 2023
A curator cannot ratify and cure proceedings founded on a plaintiff who lacked locus standi; attorney personally liable for costs.
• Civil procedure – locus standi – proceedings founded on a plaintiff lacking authority are void ab initio and not capable of ratification by a subsequently appointed curator ad litem. • Curator ad litem – scope of powers – ratification limited to acts legally capable of validation; no retrospective conferment of standing. • Costs – costs de bonis propriis – attorney personally liable for reckless or negligent conduct in pursuing void litigation. • Uniform Rules of Court (Rule 41) – withdrawal and costs where no tender made.
25 April 2023
A curator cannot retrospectively cure lack of locus standi; negligent counsel ordered to pay costs de bonis propriis.
* Procedural law — locus standi — proceedings brought by person lacking authority are void ab initio and cannot be validated by later ratification; * Curator ad litem — scope of ratification — limited to acts capable of being ratified; * Costs — costs de bonis propriis — attorneys may be mulcted where negligent, reckless or unreasonable conduct causes unnecessary costs; * Civil procedure — withdrawal of action (Rule 41) and responsibility for costs when no tender is made.
25 April 2023
Court found cumulative mitigating factors to be substantial and compelling, imposing an effective 18-year sentence and firearm prohibition.
Criminal law – Sentencing – Prescribed minimum sentences (s.51, Part 1, Schedule 2 Criminal Law Amendment Act) – Substantial and compelling circumstances – Malgas proportionality test – Sentencing triad – Murder and unlawful possession of firearm/ammunition – Declaration unfit for firearm licence.
19 April 2023
March 2023
Alleged undue influence in consenting to discharge an interim protection order requires oral evidence to determine vitiated consent.
* Civil procedure – Consent orders – Whether consent to discharge an interim protection order was vitiated by undue influence, pressure, fraud or mistake – Compromise may be set aside if consent was vitiated – Disputed facts and credibility require referral for oral evidence. * Urgent interim relief – Rule nisi and reinstatement of security protection – procedural route when applicant alleges compelled consent.
14 March 2023
A section 317 application filed after 14 days without condonation and lacking evidentiary basis is dismissed.
* Criminal procedure – section 317(1) CPA – timing and condonation – application for special entry must be made during trial or within 14 days after conviction unless condonation on good cause is obtained. * Criminal procedure – court-initiated witnesses – section 186 CPA – court will not call viva voce witnesses absent affidavits or sufficient basis on the papers. * Disclosure – alleged nondisclosure of recording of section 204 witness – where issues were ventilated at trial and on the record, relief by section 317 may be inappropriate; appeal is available.
10 March 2023
Sequestration applications dismissed: defective nulla bona returns, inadequate valuation evidence and no Master’s certificate.
Insolvency law – Act of insolvency (s 8(b)) – validity of nulla bona sheriff’s return – requirement to record amount demanded – factual insolvency (ss 9(1), 10) – adequacy of unsworn valuations and forced‑sale valuations – advantage to creditors (prospect of not‑negligible dividend) – Master’s certificate requirement (s 9(3)) – NCA registration issue raised but not determinative without collateral challenge to judgment.
7 March 2023
February 2023
Plaintiff’s amended particulars set aside as irregular for failing to plead and annex written contracts with requisite particularity.
Rule 30 – Irregular proceedings – Amended particulars set aside where pleading fails Rule 18(4) and 18(6) requirements; prejudice required; condonation of short late Rule 30(2)(b) notice permissible; leave to file fresh particulars.
21 February 2023
A material, uninitialled alteration to a written suspensive condition and failure to produce the original document rendered the sale void, so specific performance was refused.
* Property law – Alienation of Land Act s 2(1) – material terms of sale of land must be reduced to writing and signed – handwritten, uninitialled alteration to suspensive condition creates uncertainty rendering agreement void. * Evidence – best evidence rule – original document required; secondary copies inadmissible absent established exception. * Contract – suspensive condition must be pleaded and proved; non-fulfilment prevents contract becoming perfecta; waiver/estoppel cannot revive lapsed condition without proper pleadings.
14 February 2023
Application to declare regional branch meetings invalid dismissed as moot and overly broad; each party bears own costs.
Political party internal governance; party constitution as contractual agreement; members’ s19 participation rights; declaratory relief and s172 Constitution; doctrine of mootness and exhaustion of internal remedies; judicial restraint in internal party disputes.
3 February 2023
Pleadings failed to link defendant to contracts and to plead essential contractual elements, rendering refund claim vague and struck out.
Pleadings – exception for vagueness and embarrassing averments – identity and trading name allegations – must adequately link defendant to contracts relied upon – essential contractual terms and factual averments required to sustain a refund or damages claim – particulars struck out with leave to replead.
2 February 2023
January 2023
A registrar may not grant default judgment enforcing a credit agreement; only a court may under s130 NCA.
National Credit Act s130 – exclusive judicial oversight of enforcement proceedings; Registrar’s powers – Uniform Rule 31(5) and s23 Superior Courts Act do not permit registrars to grant default judgments in NCA matters; Default judgment in credit enforcement granted by registrar is null and void; Procedural – s129 notice by registered post sufficient; condonation for late replying affidavit granted.
31 January 2023
Court granted postponement for a late proposed amendment but penalised defendants with attorney-and-client costs for inexcusable delay.
Postponement — indulgence requiring full and satisfactory explanation; late applications assessed by prejudice, bona fides, and public interest; Uniform Rule 28 — amendments generally allowed unless mala fide or causing irremediable prejudice; costs — attorney-and-client costs appropriate where inexcusable delay causes unnecessary prejudice.
31 January 2023