High Court of South Africa Eastern Cape, Grahamstown - 2013

18 judgments
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18 judgments
Citation
Judgment date
November 2013
Reported
Court granted interim relief under s 49 for oppressive member conduct, divesting management and ordering access pending buy‑out valuation.
Close Corporations Act s 49 – oppressive conduct by a member – unfairly prejudicial, unjust or inequitable conduct – interim relief divesting management and compelling access to records and property – postponement to determine fair value for compulsory buy‑out; s 36 considered alternatively.
7 November 2013
September 2013
Reported
The applicant’s appeal succeeded where the trial court failed to apply prescribed minimum sentences for police fraud.
Criminal law — sentencing — failure to apply prescribed minimum sentence for fraud by a law‑enforcement officer (amounts > R10 000) — misdirection entitling appellate imposition of sentence afresh; substantial and compelling circumstances; Zinn triad; effect of abuse of police trust and harm to innocent persons.
27 September 2013
Plaintiff awarded damages for unlawful warrantless arrest and detention where police failed to show reasonable suspicion.
Unlawful arrest and detention – warrantless arrest prima facie wrongful – onus on State to prove lawfulness by objective test – s 40(1)(b) CPA (schedule 1 offences) inapplicable where officer lacked reasonable belief – damages for unlawful detention and contumelia.
19 September 2013
August 2013
Removal from a mayoral committee under s60 is an executive, not administrative, act; audi alteram partem not required.
Local government – Structures Act s60 – mayoral committee appointments and dismissals are executive powers; not administrative action under PAJA; audi alteram partem not automatically required; factual findings on non-performance upheld; executive decisions subject to legality and rationality.
29 August 2013
A court’s ruling on an application not before it is reviewable and must be set aside and remitted for proper adjudication.
Judicial review – gross irregularity where court decides an application not before it; amendment of particulars versus special pleas; prescription and s 3 notice under Institution of Legal Proceedings against Certain Organs of State Act; duties of State as litigant to act responsibly and in light of constitutional values; remittal for proper adjudication of special pleas.
23 August 2013
Confirmation of a protection order set aside for gross irregularity and denial of the respondent’s right to give oral evidence.
Domestic Violence Act (s 5(2), s 6(2)) – procedural fairness – right to be heard – gross irregularity – inadmissible reliance on complainant’s demeanour – apparent bias – review and set aside of confirmation of interim protection order – interim order extended pending rehearing before different magistrate – costs to successful reviewer.
23 August 2013
Reported
Court upheld rape and trafficking convictions after finding the child complainant credible and accuseds’ accounts patently false.
Criminal law – Sexual offences against children – Cautionary rule for single and child witnesses – Holistic evaluation of credibility; corroboration by medical and independent witness evidence; false and contradictory accused testimony as corroborative of guilt. Criminal law – Sexual exploitation and trafficking – distinct elements of offences; where lack of proof conviction must be set aside. Appeal – factual findings and application of cautionary rule not lightly interfered with.
22 August 2013
Reported
Organ of state unlawfully imported unstated tender criteria; award set aside and applicant substituted as successful bidder.
Procurement law – tender adjudication – importation of extraneous criteria and functionality not stated in tender; joint venture requirements – letters of comfort insufficient; review under PAJA and PPPFA; substitution of successful bidder versus remittal.
1 August 2013
Reported
Court affirms broad discretion under s7(1) to make divorce settlement agreements orders, rejecting Thutha’s unduly restrictive enforceability rule.
Family law — divorce — consent judgments — section 7(1) Divorce Act — court’s discretionary power to make written settlement on assets or post‑divorce maintenance an order; requirements: free consent, competence of order, not objectionable — Thutha/Mansell approach rejecting wholesale incorporation as unduly restrictive — court may consider wider interests (promotion of settlement, children’s welfare, finality, enforceability) and devise appropriate enforcement measures.
1 August 2013
June 2013
Failure to perform an invasive cavity search or use a metal detector was not negligent absent reasonable suspicion.
Delict – Negligence – Search of arrested persons; Reasonableness and foreseeability required before invasive cavity/strip-searches; Fundamental rights to privacy, dignity and bodily integrity; Searches incident to arrest; Absence of metal detector not per se negligence.
18 June 2013
The applicant failed to prove negligence for a retained surgical swab; res ipsa loquitur not applicable and claim dismissed.
* Medical negligence – retained surgical swab – mere presence of swab not conclusive of negligence; res ipsa loquitur inapplicable (Van Wyk v Lewis). * Burden of proof – plaintiff must prove negligence on a balance of probabilities; limited exception where facts are peculiarly within defendant’s knowledge may lighten evidential burden but does not shift onus. * Evidence – need for operative/theatre records or testimony to establish breach of standard of care.
14 June 2013
An arresting officer executing a magistrate’s warrant has a discretion not to arrest; failure to exercise it rendered this arrest unlawful.
Criminal procedure – arrest under warrant – discretion of arresting officer to refrain from effecting arrest once jurisdictional facts exist; Police Standing Orders and S v Sekhoto authority affirm discretion; failure to exercise discretion renders arrest unlawful; damages for unlawful arrest and detention.
5 June 2013
Appellate court found the respondent failed to justify a warrantless arrest and awarded damages to the applicant.
Criminal procedure – Arrest without warrant – section 40(1)(b) Criminal Procedure Act – jurisdictional facts for warrantless arrest – discretion of arresting officer – appellate review of trial court factual findings – damages for unlawful arrest.
5 June 2013
March 2013
Reported
Past intimate relationship with counsel, ended before trial, did not establish reasonable apprehension of bias; review dismissed.
Judicial impartiality — recusal and reasonable apprehension of bias — past intimate relationship between judicial officer and legal representative — requirement that founding papers establish grounds relied upon — Plascon‑Evans approach; constitutional right to fair hearing (s 34).
14 March 2013
Reported
Conviction overturned where inadmissible hearsay, insufficient proof of offences and unlawful search without rights explanation.
Criminal procedure — Hearsay evidence — admissibility under s3(1) Law of Evidence Amendment Act; criminal proof — insufficiency of evidence to establish fraud or alternative offences; common purpose — requirements of prior agreement or active association and mens rea; constitutional rights — s14 (privacy) and s35(1) (rights of arrested persons) must be explained before searches/detention; unlawfully obtained evidence tainted and cannot sustain conviction.
11 March 2013
Condonation granted (delay counted from date of knowledge) but rescission refused due to inadequate explanation for State's default.
Civil procedure – default judgment – rescission – condonation under Rule 60(5) and rescission under Rule 49; calculation of delay from date of actual knowledge; requirements for "good cause" and "good reason"; inadmissibility of documents taken from the bar without affidavit proof; State liability – administrative negligence in handling summons; bona fide defence insufficient alone for rescission.
1 March 2013
Failure to warn under s35 rendered a statement inadmissible, but forensic evidence established guilt beyond reasonable doubt.
* Criminal law – murder – admissibility of evidence – hearsay: out‑of‑court statement by station commander not called to testify inadmissible as hearsay. * Criminal procedure – confessions and admissions – right to remain silent and legal representation (s35 Constitution): State must prove warnings were given before incriminating statements; failure renders statements inadmissible. * Evidence – post‑mortem and expert opinion may suffice to prove cause and exclude self‑infliction hypothesis. * Appeal – exclusion of tainted evidence does not necessarily vitiate conviction where remaining evidence proves guilt beyond reasonable doubt.
1 March 2013
February 2013
Highly intoxicated, high‑speed red‑light driving causing two deaths justified a four‑year custodial sentence; appeal dismissed.
* Criminal law – Culpable homicide – Motor collision caused by driver running a red robot while highly intoxicated and at excessive speed – Two deaths. * Sentencing – Discretion of trial court – aggravating factors (intoxication, speed, city centre, flight, lack of remorse) outweigh limited mitigation (youth, first offender). * Correctional supervision – s 276(1)(h) – unsuitable where report unsupported and offender denies responsibility. * Appeal – appellate interference with sentence only for material misdirection, irrationality or shockingly disparate outcome; none established. * Argument that prison conditions render imprisonment unconstitutional rejected.
25 February 2013