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

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178 judgments
Citation
Judgment date
July 2024
Court reduced interim maintenance from R15,000 to R4,000, holding paragraph 9 was cash maintenance covering household needs, not accommodation only.
Family law – maintenance variation under rule 43(6) – interpretation of court orders – contextual/factual-matrix approach (Endumeni) – applicant’s burden to prove change of circumstances – cash maintenance vs accommodation-only payments.
9 July 2024
Leave granted to file a late counterclaim under Rule 24(1); merits and prescription reserved for trial.
Civil procedure – Uniform Rule 24(1) – condonation and leave to file late counterclaim – requirement to disclose locus standi and cause(s) of action – interlocutory application not for merits determination – prescription to be decided at trial.
9 July 2024
June 2024
Municipality's failure to respond to a billing dispute breached its credit control policy; no internal appeal required where no decision existed.
Administrative law – municipal credit control policy – failure to respond to consumer billing enquiry within prescribed 60 days – Policy has force of law – unlawful administrative conduct; Systems Act s62 – appeal requires an existing decision; no duty to exhaust internal remedies where no decision made; PAJA relief to compel decision.
18 June 2024
May 2024
Arresting officer lacked reasonable grounds and failed to exercise rational discretion; unlawful arrest and detention awarded R90,000.
Criminal Procedure Act s 40(1)(b) – arrest without warrant – requirement of objectively reasonable suspicion; jurisdictional facts from Duncan; reasonable suspicion must be based on specific, articulable facts; duty to verify complainant’s allegations where practicable; exercise of arresting discretion must be rational (Sekhoto); unlawful arrest and detention – quantum of damages – comparable authorities.
21 May 2024
Summary judgment refused where plaintiff failed to comply with NCA s129/s130 after debtor’s post‑notice settlement engagement.
National Credit Act – sections 129 and 130 – validity and efficacy of default notice depends on subsequent conduct and facts – post-notice settlement engagement may require re-issue of section 129 notice – premature summons; remedy under s130(4) is stay pending compliant notice.
17 May 2024
Rule 48 reviews allocatur-based objections; it cannot be used to compel a taxing master to proceed when taxation is stayed pending LPC proceedings.
Taxation — Review of taxation — Interpretation of Rule 48 — Rule 48 applicable to objections/disallowances and allocatur — Not a mechanism to compel taxing master to proceed — Taxing master’s discretion under Rule 70 to call for documents and await LPC disciplinary outcome.
15 May 2024
A highest scoring tenderer is not automatically entitled to a contract where the tender documents permit negotiation of market-related price.
Public procurement – tender award – highest points scorer not automatically entitled to contract where bid documents permit post-award negotiations; Preferential Procurement Regulations 2017 (transitional application) and section 217 (Constitution) – market-related pricing and value-for-money considerations; correspondence and meeting minutes can show award remains subject to negotiation.
14 May 2024
Urgent anti-dissipation interdict dismissed for non-compliance with Rule 6(12), no irreparable harm, and available alternative remedies.
* Civil procedure – Urgent applications – Rule 6(12) peremptory: founding affidavit must explicitly set out urgency and why substantial redress cannot be obtained in due course. * Interim interdict / anti-dissipation order – requirements: prima facie right, irreparable harm, balance of convenience, absence of other satisfactory remedy. * Irreparable harm – loss must be impossible or improbable to recover; mere risk of dissipation insufficient without evidence of intent. * Alternative remedies – existing court orders and review proceedings may provide satisfactory relief, negating urgent interim relief.
10 May 2024
Court assumed jurisdiction but dismissed urgent claim for estate funds because Master's consent under s26(1A) was not obtained.
* Civil procedure – jurisdiction – "causes arising" and jurisdictional connecting factors – doctrine of effectiveness and causae continentia. * Estates – Administration of Estates Act s26(1A) – release of funds for subsistence contingent on Master’s consent (jurisdictional fact). * Interim/mandatory interdict – requirement of clear right and preconditions; executors’ power to release estate funds absent Master consent. * Costs – unsuccessful urgent application: costs follow result.
10 May 2024
A restraint of trade agreement was enforced against a former employee who failed to prove a tacit new employment contract.
Labour law – employment contract – tacit contract – enforceability of restraint of trade – breach of restraint – evidence – balance of probabilities – employment relationship – restraint of trade agreements – burden of proof for tacit contracts – breach of contract by working for competitor within prohibited radius.
7 May 2024
Warrantless arrest and ensuing detention were lawful; prosecutors had reasonable cause and acted without malice.
Criminal procedure — Warrantless arrest under s 40(1)(b) CPA — objective reasonable suspicion; Bail and detention — Schedule 6 offences and s 60(11)(a) CPA; Prima facie case and prosecutors’ discretion; Malicious prosecution — requirement of reasonable and probable cause and animus injuriandi; Acquittal not determinative of malice.
6 May 2024
Leave to appeal dismissed as the matter is moot and applicants lacked reasonable prospects of success.
* Civil procedure – leave to appeal – Superior Courts Act s17 and s16(2) – mootness and lack of practical effect * Municipal law – Electricity By‑Laws – Item 6(1) and Item 21 – pre‑termination notice and prescribed methods of service * Administrative law – doctrine of legality and enforcement of municipal by‑laws * Pleadings – adequacy of founding affidavit re non‑receipt of notice; impermissibility of deciding unpleaded issues * Substantial compliance – cannot cure failure to follow imperative by‑law provisions
2 May 2024
April 2024
Res ipsa loquitur applied; respondent found 100% liable after failing to rebut applicant’s uncontradicted evidence.
* Road Accident Fund – motor collision – res ipsa loquitur – vehicle driven onto incorrect side of road – negligence and causation. * Onus – applicant’s uncontradicted evidence accepted where respondent fails to offer an explanation. * Costs – successful party awarded costs of postponement including specified expert and counsel fees. * Procedure – separation of merits and quantum (Rule 33(4)); strict compliance with Rule 36(9) expert-notice timetable required.
30 April 2024
State rebutted claim of sane automatism; accused convicted of murder but premeditation not established.
Criminal law – non-pathological criminal incapacity (sane automatism) – onus on State to rebut – expert psychological reports – voluntariness of act – conduct before, during and after incident (locking doors, procuring knife, destroying phones) – premeditation not proven.
29 April 2024
The contract took effect only on the signed execution date; the Engineer’s early commencement and the Employer’s cancellation were unlawful, entitling the applicant to proven damages.
* Contract law – commencement: execution/execution clause determines contract effective date; written signed variation required (non-variation clause). * Agency/Engineer – limits of authority: engineer cannot act ultra vires before contract formation. * Termination – unlawful repudiation where Employer in breach elects to cancel rather than remedy; constitutional/public policy balancing (Beadica). * Payment certificates – Engineer’s ruling remains in force pending adjudication/arbitration/court; dispute notice alone does not suspend payment obligation (GCC cl.10.3.3). * Remedies – Plaintiff entitled to proven damages; quantum postponed sine die; costs to successful party.
21 April 2024
Applicant may amend pleadings to alternatively challenge and seek review of a purported lease concluded without compliant procurement.
Pleadings – amendment under Uniform Rule 28 – alternative pleading challenging purported lease and seeking review; review relief against decisions of an organ of state may be pursued in action proceedings; alleged contradictions and minor typographical errors do not necessarily render pleadings excipiable; procurement and internal policy compliance relevant to validity of leases by public entities.
16 April 2024
Applicant granted interim interdict preventing municipality from giving effect to termination of its service contract pending review.
Administrative law; interim interdict pending review; procurement — RFQ appointment from panel; legality of municipal contract termination; balance of convenience and irreparable harm; joinder and urgency issues.
15 April 2024
Reinstatement of a deregistered close corporation for non‑filing of annual returns must follow CIPC’s administrative process; court cannot shortcut it.
Companies Act – deregistration for non‑filing of annual returns – reinstatement primarily an administrative remedy under s82(4) and regulation 40(6)–(7) and CIPC Practice Note; s83(4) judicial remedy does not displace CIPC requirements; urgency not established.
15 April 2024
Interlocutory application struck where main review was unserved, stayed by case management order, and improperly heard in recess.
Civil procedure — interlocutory relief dependent on main proceedings — importance of proper service; Case management orders — effect and non-suspension by out-of-time leave-to-appeal filing (Superior Courts Act s18); Practice directions — opposed applications during recess require good cause/urgency; Costs — personal liability where applicant causes wasted costs; Biowatch principle inapplicable.
5 April 2024
Leave to appeal refused: no reasonable prospects that public‑participation finding or Rule 53 approach would be overturned; costs awarded.
* Local government law – Municipal rates policy – Constitutional and statutory obligation to facilitate public participation – Adequacy of participatory process. * Civil procedure – Rule 53 review and evidence – Use of PAIA disclosure and onus in review proceedings. * Appeal – Leave to appeal – reasonable prospects of success and absence of compelling reasons. * Obiter dicta – Remarks on substantive rationality non-binding where unnecessary to outcome.
2 April 2024
Municipality obliged to enforce park by‑laws and implement management plan; court ordered access control, fencing, signage, cleaning and operator appointment.
Municipal law — constitutional and statutory duties of municipalities to administer municipal parks, refuse removal, fencing, noise and public nuisance; enforceability of provincial Operational Environmental Management Plan under Coastal Zone Regulations; municipal manager properly joined; court may grant mandatory relief to compel municipal compliance with by‑laws and environmental management measures.
2 April 2024
March 2024
Interim stay of garnishee order extended pending two-judge review; prior magistrate recusal suggests arguable bias.
Administrative law – review of magistrate’s garnishee order; judicial bias – prior recusal as indicia of reasonable apprehension of bias; interim relief – stay of execution pending review; procedure – Joint Rules requiring two-judge bench for magistrates’ court reviews; children's interests and urgency in maintenance-related litigation.
20 March 2024
An exception alleging vagueness and non-compliance with NCA s129 fails where particulars disclose the claim and no prejudice is shown.
Civil procedure – Exception (Rule 23) – Whether particulars disclose a cause of action; vagueness and embarrassment test – Onus on excipient to show prejudice – National Credit Act s129 compliance alleged but not decided on exception – Appropriateness of resolving NCA applicability to a juristic person at trial rather than by exception.
19 March 2024
Applicant qualified as deceased's next of kin; late internal appeal was a nullity; application dismissed with partial costs against respondents.
PAIA — s34(2)(e)(i) next of kin (partner/life partnership) — s18 particulars of request — s19 duty to assist and notice of intended refusal — s75(1)(a)(i) internal appeal time limits; late appeal nullity — request fee notice — costs for state PAIA non‑compliance.
19 March 2024
Municipal electricity disconnection without statutorily prescribed 14‑day notice is unlawful; reconnection and costs ordered.
* Municipal law – electricity supply by‑laws – mandatory 14‑day pre‑termination notice – methods of service prescribed by item 6(1)(a)–(e) – exclusive and peremptory. * Service – sheriff’s placing notice in post‑box (Magistrates’ Court Rule 9(5)) does not supplant specific municipal by‑law service requirements. * Administrative law – organs of state must act within empowering provisions; substantial compliance cannot cure failure to comply with peremptory statutory requirements. * Remedy – declaratory/interdictory relief confirmed; reconnection ordered and costs awarded.
5 March 2024
February 2024
The court convicted an accused of sexual assault and rape on corroborated incidents and another accused of failing to report the offences.
* Criminal law – Sexual offences – Evaluation of evidence of a single child witness and application of cautionary principles; corroboration by medical and contemporaneous reporting. * Criminal law – Rape and sexual assault – conviction where forensic evidence and distress reports corroborate complainant’s testimony. * Criminal law – Alibi – assessed in light of totality of evidence; unsupported alibi rejected. * Criminal law – Duty to report – s 54(1) Criminal Law (Sexual Offences and Related Matters) Amendment Act; forgetfulness defence requires medical proof.
29 February 2024
Service on an attorney of record and adequate short notice defeat a Rule 6(12)(c) reconsideration where the respondent wilfully absented.
Civil procedure – urgent applications and reconsideration under Uniform Rule 6(12)(c); service on attorney of record valid under Rule 4(1)(aA) and Rule 1 definition of "party"; adequacy of short notice where court directive met; purpose of Rule 6(12)(c) to protect those deprived of opportunity to be heard, not those who wilfully absent themselves; urgency and balance of convenience in stay of execution pending rescission; costs awarded including costs of opposing sheriff.
23 February 2024
Applicant proved on a balance of probabilities that a correctional officer assaulted him; respondent held liable for damages and costs.
* Prison law/duty of care – assault of inmate by correctional official – vicarious liability of Department for wrongful conduct of its officers. * Civil evidence – assessment of credibility – weight of contemporaneous medical notes and internal investigation reports; adverse inferences from failure to produce records or call witnesses. * Burden of proof – balance of probabilities in civil claims by detainees.
22 February 2024
22 February 2024
The accused were convicted of premeditated murder and unlawful firearm possession; robbery count failed due to owner consent.
Criminal law – common purpose and premeditated murder; admissibility of evidence – police interrogation, right to legal representation and self-incrimination; accomplice evidence – cautionary approach and corroboration; robbery – absence of intention where owner consents; minimum sentences – Malgas principles and assessment of substantial and compelling circumstances.
14 February 2024
Applicant's expulsion set aside for procedural unfairness after tribunal refused postponement pending criminal proceedings.
Administrative law – student disciplinary proceedings – procedural fairness – refusal to postpone pending related criminal proceedings – right to reasonable opportunity to present defence – PAJA ss3(1),3(3)(b) – rule 53 record – representation limited by student disciplinary code.
8 February 2024
January 2024
Late review of discretionary grant allocation was unreasonably delayed; condonation denied and application dismissed with costs.
Administrative law – PAJA – section 7(1) time period and condonation – commencement date of 180 days; exhaustion of internal remedies under Lotteries Act s26H; discretionary grant allocations — budgetary constraints and regulation of capping principle; allegations of corruption and SIU reports insufficient to excuse delay without corroborating evidence.
9 January 2024
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