High Court of South Africa Eastern Cape, Grahamstown - 2022

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110 judgments
Citation
Judgment date
December 2022
Partial demolition ordered for outbuilding unlawfully encroaching building line, subject to engineer’s safety certificate.
Building law – building line encroachment – National Building Regulations – absence of proven written consent by neighbouring owner – prescription inapplicable to demolition declarations – discretionary and proportionate remedy: partial demolition subject to engineer’s certificate; costs.
15 December 2022
Execution pending appeal requires exceptional circumstances, irreparable harm to applicant and absence of irreparable harm to respondent.
Superior Courts Act s 18 – suspension pending appeal is norm – execution pending appeal is exceptional; applicant must prove (1) exceptional circumstances, (2) on a balance of probabilities irreparable harm to applicant if not executed, and (3) absence of irreparable harm to respondent if executed; mere assertions insufficient; prospects of success relevant but do not replace statutory twofold test.
14 December 2022
Applicant failed to establish a prima facie right to interim relief suspending his party suspension; application dismissed with costs.
Disciplinary law – internal party disciplinary cascade – NDCA and NEC jurisdiction; Interdictory relief – Setlogelo test applied to intra-party disciplinary suspension; Interpretation – contextual approach to ANC constitution; Interim relief – prima facie right, irreparable harm, balance of convenience; Costs – ordinary rule with allowance for two counsel in complex urgent litigation.
14 December 2022
Applicant’s urgent interdict failed: sale agreement was cancelled, urgency self-created and conduct amounted to abuse of process.
Interdict pendente lite — requirements: prima facie right, irreparable harm, absence of ordinary remedy, balance of convenience; Sale agreement cancelled — purchaser cannot claim specific performance where cancellation is undisputed; Urgency — must not be self-created; Abuse of process — repeated meritless litigation justifies punitive costs; Costs — attorney-and-own-client, taxable immediately.
13 December 2022
Rescission refused: applicants failed to prove delay explanation, service or locus standi defects, or prima facie defence.
Civil procedure — rescission under Rule 42(1) — requirements: reasonable explanation, good faith, bona fide defence with prima facie prospects — service of process and sheriff’s jurisdiction — locus standi of lessee/trust where letters of authority and lease exist — permission to occupy lapses on death.
13 December 2022
Application for rescission of an order restraining alleged unlawful occupation dismissed due to lack of a bona fide defense.
Civil Procedure – Rescission of Order – Jurisdiction of Sheriff – Locus Standi – Service of Court Process – Rule 42 of Uniform Rules.
13 December 2022
13 December 2022
Leave to appeal to the SCA granted in a review of an exploration right raising PAJA, consultation and language issues.
Administrative law — judicial review of administrative action — exploration right and seismic survey — meaningful consultation with affected communities — language and notice obligations — undue delay — PAJA ss 3 and 4 interplay — exhaustion of internal remedies — leave to appeal to Supreme Court of Appeal granted due to statutory-interpretation and public-importance considerations.
13 December 2022
Under amended rule 32, an evasive plea and unsupported oral compromise cannot defeat summary judgment for a secured loan.
* Civil procedure – Summary judgment under amended rule 32 – plaintiff must engage with the plea to show defence not bona fide. * Pleadings – Rule 18(5) – bald denials and evasive pleas impermissible. * Defence – requirement of bona fide and good defence: full disclosure of nature, grounds and material facts. * Contract – compromise/novation requires prior dispute; oral variation invalid where express non-variation clause requires written variation. * Execution – ancillary rule 46A sale in execution application may be deferred pending summary judgment.
12 December 2022
Acquittal where prosecution failed to prove accused subjectively foresaw complainant’s incapacity to consent.
Sexual offences — incapacity to consent — definition of "person with a mental disability" under Sexual Offences Act; mens rea in rape — subjective foresight and honest belief in consent; inferential reasoning — only the sole reasonable inference may establish subjective foresight; testimonial competence of persons with intellectual disabilities — role of expert evidence and reasonable accommodations.
12 December 2022
Main seat of Eastern Cape High Court has concurrent jurisdiction; lis pendens failed because causes of action differ.
* Civil procedure — rescission of judgment — distinction between quantification proceedings and rescission proceedings — lis pendens not established where causes of action differ. * Superior Courts Act s6 — main seat (Makhanda) has concurrent jurisdiction over local seats in Eastern Cape. * Jurisdiction — rescission may be heard at main seat despite judgments granted at local seat. * Plea of appeal disguised as rescission — court will examine cause of action to determine genuine rescission.
6 December 2022
Court upheld a section 65A payment order, finding the appellant's life-insurance premiums may be used to satisfy respondents' judgments.
Magistrates' Court Act s65A — inquiry into financial position of judgment debtor — discretion to make just and equitable payment orders — life insurance premiums not a basic necessity and may be redirected to satisfy judgment debts — enforcement of default judgments by monthly instalments.
2 December 2022
Leave to appeal granted where reasonable prospects exist that a joint‑venturer may enforce its pro rata contractual rights independently.
* Civil procedure – exception for vagueness and embarrassment – failure to plead basis to enforce rights arising from joint‑venture contract. * Contract/partnership law – joint venture co‑creditor rights – whether a joint‑venturer may claim pro rata share independently. * Leave to appeal – section 17(1)(a)(i) Superior Courts Act – reasonable prospects of success required.
2 December 2022
Leave to appeal granted against general damages award due to reasonable prospects of a materially higher award on appeal.
Civil procedure – leave to appeal – quantum of damages – trial court’s wide discretion in assessing general damages – appellate interference where reasonable prospects exist of materially higher award.
1 December 2022
November 2022
Attesting a forged signature in the signatory’s absence constitutes misconduct warranting suspension, though dishonesty must be proved for striking off.
Professional misconduct — attestation of signatures — witness attesting in absentia to forged signature — balance of probabilities establishes misconduct though dishonesty not proved — appropriate sanction: suspended suspension — regulator’s investigatory duties.
29 November 2022
Police who merely act on prosecutorial instructions do not necessarily 'set the law in motion' nor are they liable absent proof of malice.
Malicious prosecution — requisites: setting the law in motion, absence of reasonable and probable cause, malice, and failure of prosecution; investigating officer acting on prosecutor's instruction does not necessarily ‘set the law in motion’; withdrawal of charges/absence of prima facie case insufficient to establish malice; distinction between unlawful arrest and malicious prosecution and respective onuses.
29 November 2022
Leave to appeal granted because encroachment/expropriation issues raise compelling constitutional and public-law importance.
Leave to appeal — s 17(1) Superior Courts Act — test requires reasonable prospects of success or compelling reasons — leave granted where matter raises public importance relating to encroachment/expropriation, municipal competence and property rights; costs of leave application to be costs in appeal.
29 November 2022
A reliable DNA match can alone support conviction if, on the facts, it excludes every reasonable alternative inference.
DNA evidence — expert and circumstantial evidence; admissibility and probative value determined by chain of custody, sample quality, STR match and statistical frequency; no general requirement for corroboration; inferential reasoning under Blom; alibi assessed against totality of evidence.
29 November 2022
Board unlawfully repudiated a Fidelity Fund claim by relying on a belated time-bar after requesting further proof.
* Sheriffs Act s 35, s 36(2)(a) & (b), s 36(3) — time for lodging Fidelity Fund claims; election to require proof under (b) removes reliance on (a). * Administrative law — review for irrationality, ulterior purpose and failure to consider relevant considerations (PAJA s 6(2)). * Requirement to exhaust remedies against sheriff (s 37) — scope and application vis-à-vis Fund claims. * Conduct of statutory bodies — obligation to act fairly, assist claimants and not rely on inconsequential technicalities. * Costs — punitive attorney-and-client costs where respondent’s conduct obstructs deserving claimants.
22 November 2022
Appellants held in civil contempt for refusing to pay reinstated status quo ante fuel price; appeal dismissed.
Civil contempt – standard of proof on a balance of probabilities where committal not sought; Interpretation of orders – orders must be read with the reasons to ascertain intention; Reinstatement of status quo ante in urgent relief includes price where intended by reasons; Procedural non‑compliance and condonation – lapsed appeal and refusal to reinstate; Costs – punitive attorney and client scale with costs of two counsel.
22 November 2022
Identification and accomplice evidence were unreliable; recent-possession and alibi issues meant convictions could not stand.
* Criminal law – identification evidence – dock and CCTV-based identifications after significant lapse of time require caution and corroboration. * Criminal procedure – section 204 accomplice discharge – irregular to discharge before conclusion of case; accomplice evidence requires close scrutiny. * Evidence – doctrine of recent possession – requires proof that property found was the stolen property; absent identification, doctrine inapplicable. * Criminal law – alibi – State must disprove alibi beyond reasonable doubt; failure to do so undermines conviction.
15 November 2022
Rescission granted: acceptable explanation for default and a prima facie defence as to game-count justified setting aside default judgment.
Rescission of default judgment; common law "sufficient cause" requires reasonable explanation for default and a bona fide defence with some prospect of success; wilful/default conduct relevant but not determinative; sale of property including game — dispute as to game-count (Annexure A1) can found prima facie defence; statutory permits and fencing compliance not established as prima facie defence.
8 November 2022
A magistrate’s cumulative courtroom interventions gave rise to a reasonable apprehension of bias, warranting review and retrial.
* Criminal procedure — Recusal and review — Reasonable apprehension of bias — Leading/questioning by presiding magistrate potentially augmenting State case may found objective apprehension of bias under s 22(1)(b) Superior Courts Act; * Review of lower court proceedings — High Court intervention justified where refusal to recuse risks grave injustice; * Delay/condonation — multi‑factor enquiry, merits may outweigh delay; * Relief — setting aside refusal, referral to DPP for re‑arraignment and de novo trial before another magistrate.
8 November 2022
Leave to appeal refused — no reasonable prospect another court would reach a different conclusion.
Appeal — Leave to appeal — s17(1) Superior Courts Act — test whether another court may reasonably reach a different conclusion; Procedural non-compliance — whether non-compliance excused where no prejudice — Miller v Natmed distinguished; Costs — no order where respondents did not oppose leave application.
8 November 2022
Interim interdict refused where applicants failed to show a prima facie right, urgency was self‑created, and balance of convenience favoured respondents.
Interim interdict – requirements for interim relief – prima facie right, irreparable harm, alternative remedy, balance of convenience; urgency and self‑created urgency; enforceability of joint venture/co‑operation agreements vis‑à‑vis Marine Living Resources Act and small‑scale fishing policy; departmental discretion to allocate permits.
2 November 2022
An executrix cannot plead rei vindicatio or seek transfer absent clear allegation of full ownership; particulars were excipiable.
Succession law – executor’s locus standi and administration of estate; Property law – rei vindicatio requires allegation of full dominium; Civil procedure – pleadings must comply with Rule 18(4) and not be vague or embarrassing; Eviction – PIE relief dependent on competent ownership pleading.
1 November 2022
Service at the applicant's chosen domicilium was effective; she failed to show good cause or a prima facie bona fide defence.
* Civil procedure – rescission – application to rescind judgment dismissing earlier rescission application – requirements under common law for good cause (reasonable explanation and bona fide defence). * Service – domicilium citandi et executandi – service on occupant at chosen domicilium effective under rule 4(1)(a)(iv). * Uniform rule 42(1)(a) – rescission only where order was erroneously sought or granted in absence of affected party; alleged rule 18 non-compliance not ordinarily a basis for rule 42 relief. * Condonation – balance of finality and interests of justice; slender explanation insufficient.
1 November 2022
October 2022
Accused convicted of armed robbery-related offences and murder of a co-perpetrator under common purpose and dolus eventualis.
* Criminal law – Common purpose and joint liability – armed entry and attempted robbery – imputation of possession of firearm and ammunition to co-perpetrator. * Criminal intent – dolus eventualis established where accused subjectively foresaw potentially fatal resistance during armed attack. * Evidence – credibility and physical evidence (footprints, ballistic, photographs) fatal to accused’s inconsistent version. * Firearms – unlawful possession proven where accused took, hid and attempted to dispose of a semi-automatic pistol with erased serial number.
28 October 2022
Applicant failed to show proper execution of movables; unreliable nulla bona return precluded ordering execution against respondent’s home.
Execution — Uniform Rules 45 and 46 — requirement to attempt and properly record execution against movables before ordering immovable (primary residence) executable — reliability and impeachment of sheriff's nulla bona return — evidentiary weight of returns of service.
25 October 2022
Warrantless arrests require an objective reasonable suspicion; some assault findings overturned and damages substantially reduced.
Criminal procedure – warrantless arrest under s 40(1)(b) – reasonable suspicion is an objective, fact-specific test based on information available to arresting officer; no general duty to verify suspects’ exculpatory statements; credibility of arresting officer and quality of informer’s information critical. Delict – actio iniuriarum and unlawful arrest/detention – quantum assessed against duration, nature of infringement, presence of assault and comparable awards. Costs follow result.
25 October 2022
Contractor lawfully suspended works under FIDIC for non‑payment; applicant’s urgent plea to compel resumption was dismissed.
Contract law; FIDIC DBO contract – clauses 14.8 (payment of interim certificates) and 16.1 (contractor’s entitlement to suspend); validity and sufficiency of contractual notices; interim relief and specific performance pending dispute resolution; urgency and public interest in water supply; effect of subsequent DAB decision on payment certificates.
25 October 2022
Section 18 execution application struck from the roll for self-created urgency and an unreasonable, prejudicial timetable.
Urgency — section 18 Superior Courts Act — whether section 18 proceedings automatically justify extreme urgency — self-created urgency — unreasonable timetable — striking application from roll — wasted costs — case flow management by Judge President.
25 October 2022
Court refuses interlocutory intervention, finding fraud and forgery charges sufficiently particular and no gross irregularity.
Criminal procedure – interference in unterminated proceedings – review in medias res – exceptional relief only where gross irregularity or grave injustice threatens; Criminal procedure – particularity of charge – s84(1) CPA and s35(3)(a) Constitution – fraud and forgery charges held sufficiently particular; Forgery – prosecutor may state identity unknown under s84(2) without rendering charge defective; Mandamus to compel particulars not granted where no exceptional prejudice shown.
21 October 2022
A final fraud conviction renders the respondent unfit to practise; section 40(8) does not bind the Council.
Professional misconduct – conviction for fraud as prima facie proof of unfitness to remain on roll; Legal Practice Act s40(8) – does not make disciplinary committee’s recommended sanction final or preclude Council from seeking different relief; High Court retains ultimate supervisory disciplinary jurisdiction; Procedural points (s40(3)(a)(i), Uniform Rule 7, deponent authority) dismissed.
20 October 2022
Accused on parole failed to discharge onus for bail due to unlawful firearm possession and risk of Schedule 1 reoffending.
Bail — Schedule 5 — onus on accused (s60(11)(b)) to show interests of justice permit release; s60(4)(a) likelihood of committing Schedule 1 offence; s60(5) factors (violence/disposition to reoffend); parole status and unlawful possession of a (stolen) firearm; appeal court will not interfere absent demonstration that lower court was wrong.
19 October 2022
Surrendered suspect was forcibly manhandled; court found use of force unlawful and awarded damages and costs.
* Police law – use of force – section 27(1) Criminal Procedure Act – force must be reasonably necessary to overcome resistance; surrendered suspect cannot be lawfully subjected to unnecessary force. * Evidence – adverse inference – test for drawing inference from failure to call witnesses; availability and evidential value must be considered. * Civil liability – assault and actio iniuriarum – causation of injuries by police conduct and award of damages. * Appellate review – misdirection by trial court allows re-evaluation of credibility and probabilities.
18 October 2022
A restraint of trade clause was enforced against a former business owner joining a rival, but not against the new employer absent unlawful competition.
Restraint of trade – Interpretation and enforceability – Comparable businesses operating in same sectors and regions – Requirements for final interdict – Burden for interdicting non-contracting competitor employer – Proof of competitive overlap and potential harm – Absence of evidence of unlawful competition by third party employer.
18 October 2022
The 14‑day DEO decision limit in Regulation 19.4 is a procedural time‑bar and may be extended for good cause.
Education law – School Governing Body elections – Regulation 19.4 – 14‑day period for DEO decisions – procedural (extendable) time‑bar, not substantive; purposive interpretation to avoid absurdity.
18 October 2022
Default judgment prematurely granted — constitutes good reason for rescission; appeal upheld and judgment set aside.
Magistrates' Courts — Rescission of default judgment — Rule 49 requires good cause or separate "good reason" — Court must consider reasonable explanation for default and bona fide defence — Default judgment prematurely sought/granted before expiry of notice period constitutes good reason to rescind — Costs awarded against party who prematurely sought default judgment.
18 October 2022
Applicants must exhaust the section 30 regulatory remedy before seeking judicial review under PAJA.
PAJA – s7(2) mandatory exhaustion of internal remedies; Electricity Regulation Act – s30 as internal remedy; administrative review – non‑exhaustion bars PAJA review; no discretion to postpone where s7(2)(b) applies; exceptional circumstances under s7(2)(c) not established.
18 October 2022
Court upheld prescribed minimum sentence for robbery; no substantial and compelling circumstances to deviate.
Criminal law – sentencing – robbery with aggravating circumstances – prescribed minimum sentence; sentencing discretion on appeal – test for interference; consideration of pre-trial custody and concurrent sentences; aggravating effect of weapon use even without physical injury.
18 October 2022
An appellate court will not disturb a prescribed-minimum murder sentence absent material misdirection or demonstrable substantial and compelling circumstances.
* Criminal law – Murder – Minimum sentences under Criminal Law Amendment Act – whether substantial and compelling circumstances justify deviation from 15 years. * Sentencing – appellate review – Malgas test; deference to trial court absent material misdirection. * Mitigation – alleged jealousy/‘crime of passion’ and diminished responsibility must be placed on record by accused; courts will not speculate. * Comparative authorities distinguished where factual bases for mitigation existed.
18 October 2022
Applicant entitled to R15,000 monthly pendente lite credit‑card payments; trust obligations cannot be enforced in Rule 43 against a non‑party.
* Civil procedure – Rule 43 pendente lite relief – limits of Rule 43 where obligations are those of a trust not a party to the proceedings; * Interim maintenance – entitlement to interim personal payments during divorce proceedings; * Interim legal costs – assessment of reasonableness and reduction where mediation likely; * Costs – usual order that costs follow main proceedings.
11 October 2022
Applicant’s urgent bid for free access to a former matrimonial home to collect belongings dismissed; items already packed and ordinary remedies available.
Family law – access to former matrimonial home barred by domestic violence interdict – applicant’s right to collect personal effects – Plascon-Evans approach to disputed facts in motion proceedings – availability of rei vindicatio or damages as ordinary remedies – costs.
11 October 2022
Applicant was refused urgent access to the former matrimonial home after the respondent had already packed and made his belongings available for collection.
Family law – Divorce – Access to former matrimonial home – Collection of personal property – Rights of access where personal belongings already packed and made available for collection – Urgent interdictory relief – Availability of alternative remedies.
11 October 2022
Failure to properly consider correctional supervision and a deficient report vitiated the sentence, requiring remittal for fresh sentencing.
* Sentencing – Correctional supervision – s 276(1) – trial court must give proper consideration to correctional supervision and its possible conditions (house arrest, community service, district restriction). * Sentencing – Adequacy of correctional supervision report – deficient or perfunctory reports may vitiate sentencing discretion. * Sentencing – Serious violent offences – gravity and deterrence are relevant but do not absolve court from considering non-custodial options and the offender’s personal circumstances. * Appeal – interference justified where trial court committed material irregularity in exercising sentencing jurisdiction.
5 October 2022
Unilateral cessation of consent‑order maintenance was wilful contempt; appeal and rescission/new‑evidence applications dismissed.
Family law – maintenance – enforcement of consent maintenance order – civil contempt proceedings – requisites: order, service/notice, non‑compliance, wilfulness and mala fides (Fakie test); consent order enforceability; rescission/new evidence applications under Rule 42 and s 19(b)/s 173 – inadmissible where evidence available earlier and no explanation; inability to pay defence – evidential burden on defaulter; appellate interference only for misdirection of fact.
4 October 2022
Arrest under s40(1)(b) was lawful; interest on delictual damages runs from judgment; cross-appeal dismissed.
Criminal Procedure Act s40(1)(b) – arrest without warrant – objective reasonable suspicion – exercise of discretion to arrest must not be arbitrary, irrational or mala fide and must be properly pleaded; continued detention – lawfulness assessed on pleaded grounds and factual evidence; delictual non-pecuniary damages assessed at date of judgment — interest runs from judgment (or a short period thereafter); appellate interference with trial court costs order limited to misdirection or absence of grounds.
4 October 2022
September 2022
Cellphone, ballistic and similar-fact evidence proved conspiracy to steal rhino horn and unlawful firearm possession.
* Environmental/criminal law – Rhino poaching and theft – statutory conspiracy to steal rhino horn. * Evidence – Similar-fact evidence – admissibility of cellphone tower data, prior poaching incidents and ballistic linkage. * Forensic evidence – Ballistics linking weapon to prior killings as circumstantial proof. * Firearms law – Unlawful possession of a large-game rifle and ammunition; common purpose and associative liability.
30 September 2022
Writ and attachment set aside where attorneys acted without valid mandate; post-dated resolution invalid and punitive costs awarded.
Civil procedure – application to set aside writ of execution and notice of attachment – authority to act for company – validity of post-dated board resolution – intervention/joinder – punitive costs (attorney and client) for counsel acting without valid mandate.
27 September 2022