High Court of South Africa Eastern Cape, Grahamstown - 2024

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140 judgments
Citation
Judgment date
December 2024
High Court overturns magistrate's refusal of bail, emphasizing interests of justice in extradition cases.
Extradition proceedings – Bail pending appeal – Inappropriate application of Coetzee formulation – Interests of justice as benchmark.
30 December 2024
Plaintiff validly cancelled lease under clause 21.1.1 without seven‑day notice; absolution from instance dismissed.
Lease law – breach and cancellation – interpretation of multi-part breach clause (clause 21.1) – sub-clauses construed as independent grounds for cancellation; clause 21.1.1 permits immediate cancellation for non-payment on due date. Suretyship – renunciation of benefits of excussion and division – plaintiff not required to obtain judgment or exhaust remedies against deregistered principal debtor before suing surety. Civil procedure – absolution from instance – prima facie case required; application dismissed.
18 December 2024
Rescission of default judgment dismissed for failure to show reasonable explanation for default and prima facie defence.
Rescission of default judgment — requirements: reasonable and satisfactory explanation for default and bona fide defence with prima facie prospects; section 129 National Credit Act — notice and consumer protection obligations; sheriff's return and track-and-trace evidence constitute prima facie proof of service; debtor’s duty to discharge balloon payment after debit order lapse; condonation considered but does not cure substantive failure to meet rescission test.
17 December 2024
An exception failed: the amended particulars disclosed a cause of action despite reliance on an unpleaded suspensive clause.
Exception — pleading to disclose cause of action — suspensive contractual condition — clause requiring endorsement/authentication — interpretation of contract inappropriate on exception — authenticity of invoices and certification are trial issues — alternative claim of unjustified enrichment.
17 December 2024
A children’s court order granting grandparent contact was upheld and refined under the Children’s Act in the children’s best interests.
Children’s Act s 23 – contact (access) applications; best interests of the child paramount; social-work reports material; implacable opposition by custodial parent without evidence of harm insufficient to deny contact; structured orders and limited supervision to minimise conflict.
10 December 2024
Leave to appeal granted because non-joinder of officials personally gives a reasonable prospect of success on appeal.
Contempt of court – committal proceedings – requirement for joinder/personal service of officials in their personal capacities where deprivation of liberty is a possible consequence – application of Matjhabeng and Pheko; Leave to appeal – s 17(1)(a) Superior Courts Act – reasonable prospect of success; Constitutional right to freedom and security (s 12(1)).
5 December 2024
Rescission refused: company lacked satisfactory explanation and prima facie bona fide defence despite director's standing.
Companies — Rescission of winding‑up orders — standing: company may, through its directors, apply to rescind a winding‑up order without liquidator’s co‑operation; Service — proper service on company, its attorneys and director is crucial; Rescission — applicant must show satisfactory explanation for default and a bona fide defence with prima facie prospects of success; Section 354 — requires exceptional/special circumstances to set aside winding‑up order; Insolvency — existence of security alone insufficient to negate commercial insolvency without supporting particulars.
3 December 2024
Defendant’s white-line warning was inadequate; owner liable for trip injury from uneven mall paving.
Delict – negligence – duty of care of landowner to invitees; adequacy of warnings for an uneven change in floor level; evidentiary weight of expert opinion without factual foundation; causation in cases of negligent omission (but-for and common-sense analysis).
3 December 2024
November 2024
Applicant failed to show prima facie right or irreparable harm to justify interdicting a municipal procurement process.
Public procurement — interim interdict pending review — rationality of specific preferential goals and point-weighting under PPPFA and SCMP — requirements for urgent interim relief (prima facie right, irreparable harm, balance of convenience) — separation of powers considerations in restraining public procurement.
27 November 2024
Eviction refused where genuine dispute over payments and entitlement to transfer; referral to oral evidence on payment computation and transfer.
PIE – eviction by owner – court must consider if eviction is just and equitable, balancing owners' and occupiers' rights. NCA – distinction between incidental credit agreements and credit agreements; interest charged only on default may indicate an incidental agreement not requiring registration. Settlement agreements – enforceability and misrepresentation; consensual novation of payment obligations. ALA s27(1) – purchaser entitled to demand transfer on payment of not less than 50% of purchase price; disputes over computation of payments may require oral evidence. Procedure – material disputes of fact in motion proceedings warrant referral to oral evidence or trial.
26 November 2024
Leave to appeal granted where delegation compliance and signature placement raised a reasonable prospect that the loan agreement was valid.
Superior Courts Act s17(1)(a) – leave to appeal – reasonable prospect of success; Delegation of powers – authority to sign loan agreements; Land and Agricultural Development Bank Act s26 – categorisation of loan agreements and signatory requirements; Signature placement – whether signing in witness space precludes signatory authority; Contract enforcement – pacta sunt servanda and public policy (Pridwin/Barkhuizen).
25 November 2024
Whether substantial and compelling circumstances justified departing from prescribed life sentence for the accused who raped an 11‑year‑old.
Criminal law – Sexual offences – Rape of a child under 16 – Plea in terms of s112(2) CPA – Sufficiency of written plea; Sentencing – Prescribed minimum life sentence under s51(1) and Schedule 2 – Substantial and compelling circumstances to justify departure (Malgas, Vilikazi); Sentencing triad (Zinn) – balancing aggravating impact on child and accused’s mitigation; Ancillary orders – entry on National Register for Sex Offenders; court‑ordered psychotherapy via Department of Social Development.
22 November 2024
Leave to appeal refused: condonation properly granted as prescription and prejudice were not established by the municipality.
Institution of Legal Proceedings against certain Organs of State Act – condonation under s3(4) – good cause and unreasonable prejudice assessed by overall impression (Madinda). Prescription – section 12(3) Prescription Act – knowledge of facts and identity of debtor; mixed question of fact and law (Gericke; Mtokonya). Pleading on prescription – defendant must allege and prove date on which creditor acquired requisite knowledge. Leave to appeal – s17(1)(a) Superior Courts Act – reasonable prospects of success and absence of compelling reasons. Prejudice – requires specific factual basis; general assertions of fading memories/records insufficient.
21 November 2024
Respondents’ payment of arrears reinstated the credit agreement; proceedings were premature due to defective Section 129 notice.
National Credit Act s129(3) — remedying default and reinstatement by payment of arrears and charges; s129(1) — notice must reach consumer before enforcement; requirement to prove notice reached each consumer; Rule 46 and executability of immovable property — need for nulla bona / special executability and consistency with section 26 right to housing.
19 November 2024
Second bail application failed: purported new facts were not exceptional under section 60(11)(a); appeal dismissed.
Bail — Schedule 6 offences — section 60(11)(a) C.P.A. — "new facts" requirement — exceptional circumstances — burden on accused (balance of probabilities) — interests of justice — witness intimidation, evidence concealment and flight risk — appeal standard under section 65(4).
19 November 2024
The respondent lawfully terminated the applicants' board appointments for failing mandatory statutory nomination requirements.
Administrative law – Water Services Act – Schedule 1 item 3(5) – peremptory requirement for written nomination signed by proposer and seconder – non-compliance renders appointment invalid. Administrative law – Section 35(5) WSA – Minister’s power to terminate Water Board appointments – lawful where jurisdictional facts for appointment absent. Procedure – Motion proceedings – Plascon-Evans rule – applicants may not raise new facts in reply; unresolved factual disputes favour respondent. Doctrine of legality – courts enforce mandatory statutory preconditions; public power must remain within law.
19 November 2024
The respondent’s reconvention was largely excipiable for failing to plead material facts and the basis for enrichment.
Civil procedure – exception to reconvention – pleading requirements under Uniform Rules 18(4), 18(6) and 18(10) – distinction between facta probanda and facta probantia – failure to attach written agreement not necessarily fatal where material terms are pleaded – requirements for pleading duress, misrepresentation, lack of consensus and enrichment causes of action (negotiorum gestio / condictio).
19 November 2024
No substantial and compelling circumstances justified departing from life imprisonment for a premeditated murder committed in furtherance of a common purpose.
Criminal law – sentencing – section 51(1) CLAA prescribed life sentence; substantial and compelling circumstances; common purpose and premeditation; primary caregiver considerations; lack of remorse and rehabilitative prospects; aggravating conduct (luring, concealment, breach of professional trust); sentence for attempted murder.
18 November 2024
An intention to apply for asylum does not automatically entitle an undocumented foreigner to release on bail; magistrate’s refusal upheld.
Criminal procedure – Bail appeal – appellate interference only where magistrate misdirected in law or fact; Immigration law – unlawful entry/remain (s49(1)(a)) – expired permit and unexplained delay in seeking asylum can justify refusal of bail; Refugee/Immigration interface – expression of intention to apply for asylum does not automatically entitle release; State duty – Department of Home Affairs must take reasonable steps to facilitate asylum application (Regulation 8).
1 November 2024
October 2024
Accused convicted of murder and attempted murder for actively associating in a common-purpose shooting; robbery not proved.
Criminal law – Common purpose – active association: presence at scene, awareness, intention, an act manifesting association and mens rea (dolus eventualis) required for liability. Evaluation of witness statements – omissions in initial police statements not necessarily fatal where explained by trauma and proper holistic assessment. Circumstantial evidence – link between accused and third party life policy can be admissible motive/evidential inference. Single witness corroboration – small corroborative facts may suffice to support single witness evidence.
31 October 2024
Applicant entitled to further interim payment under rule 34A for medical costs and loss of earnings; respondent failed to rebut expert evidence.
Interim payments — Rule 34A URC — Requirements: claim limited to medical costs and loss of income and judgment/admission of liability — Substantial compliance with rule 34A(2) by reliance on expert reports previously served — Respondent must place positive evidence to create real dispute — Court may order substantial interim payment and prescribe timetable for early trial.
29 October 2024
Trustees had authority, statutory requirements met, trust committed acts of insolvency and final sequestration granted.
Insolvency — trustees’ authority and Master’s certificate — compliance with s9(3)(b); Acts of insolvency — dispositions and attempted removal of property (s8(c),(d)); Liquidated claim requirement (s9(1)) — loan payable on demand; De facto insolvency — liabilities exceeding assets; Advantage to creditors — concursus and supervised realization of assets.
24 October 2024
Whether exceptional circumstances justify bail for Schedule 6 child sexual offences where accused lives next to complainant.
Bail — section 60(11)(a) (Schedule 6 offences) — exceptional circumstances; section 60(4) factors — risk of influencing/intimidating witnesses; proximity of accused and complainant; new facts on appeal — section 65(2); relocation as bail mitigation; child sexual offences.
22 October 2024
Court stayed winding-up order and arrest warrants pending rescission hearing, finding urgency and risk to personal liberty.
Companies law – winding-up order – stay of execution pending rescission; Urgent procedure – Rule 6(12) – dispensing with forms; Suspension of execution – Rule 45A – real and substantial justice; Effect of respondent not filing answering affidavit in urgent applications; Rescission procedure – Rule 42(1)(a) vs Companies Act remedies.
22 October 2024
Whether a hire‑purchase agreement concluded without MFMA/SCM budgetary and procurement compliance is unlawful and void ab initio.
Public procurement; MFMA and SCM policy compliance; IDP and adjustments budget requirements for capital projects; constitutional procurement (s217); sole‑supplier deviation; unlawfulness and voidness of contract; referral for remedial determination under s172(1)(b).
22 October 2024
A magistrate cannot summarily fine a bail accused under s67A; proper criminal or s67 procedures are required.
Criminal procedure – Bail defaults – s67 and s67A Criminal Procedure Act – section 67A creates an offence and requires ordinary criminal procedure and proof; section 67 prescribes provisional cancellation, forfeiture and 14‑day rule; magistrate may not summarily enquire and fine under s67A.
22 October 2024
Composite conviction set aside where theft was uncompleted; conviction limited to housebreaking with intent to steal and sentence suspended.
Criminal law – housebreaking with intent to steal and theft – composite or 'rolled-up' charge – single intent/continuous transaction test; duplication of convictions; review under s304(4) CPA; sentencing – misdirection, shockingly inappropriate sentence, substituted wholly suspended sentence; antecedence of sentence.
18 October 2024
Plaintiff failed to prove, on a balance of probabilities, that an unknown insured driver’s negligence caused the accident; claim dismissed.
Road Accident Fund – liability for bodily injury – necessity for plaintiff to prove on balance of probabilities that accident was caused by negligent insured driver. Evidence – credibility and consistency of pleadings, witness testimony and police accident report – material contradictions undermine causal finding. Absence of defendant evidence does not relieve plaintiff of onus.
15 October 2024
An appellate court upheld a life sentence for rape, finding no substantial and compelling circumstances to justify a lesser sentence.
Criminal law – Minimum sentences – s 51(1) and (3)(a) Criminal Law Amendment Act – life sentence for rape where prescribed – when substantial and compelling circumstances justify deviation. Sentencing – relevance of age and plea of guilty – both may be neutral absent evidence of immaturity or genuine remorse. Appellate review – interference with minimum sentences limited to irregularity, misdirection or unreasonableness.
11 October 2024
Arrests and detentions at a roadblock were lawful under s40(1)(a) and s40(1)(b) CPA; civil claims dismissed, matter referred to NPA.
Criminal procedure – arrest without warrant – s40(1)(a) and s40(1)(b) Criminal Procedure Act – reasonable suspicion test – objective grounds for arrest; detention – s50 CPA and constitutional right against arbitrary deprivation of liberty; admissibility/value of unpleaded allegations of torture; referral to NPA for reconsideration of prosecution.
8 October 2024
The applicant proved driver negligence; apportionment unavailable where the respondent failed to plead contributory negligence.
Road Accident Fund – s17(1) RAF Act – plaintiff must prove delictual elements; Identity discrepancies corroborated by witness and hospital affidavit; Contributory negligence/apportionment require that plaintiff’s fault be placed in issue in pleadings; Defendant’s bare denial insufficient to invoke Apportionment of Damages Act; Costs awarded to successful litigant.
8 October 2024
Applicant failed to plead or prove detriment or refusal to account; trustee removal application dismissed.
Trusts – removal of trustees – section 20(1) Trust Property Control Act – removal requires detriment to beneficiaries or imperilment of trust assets; pleadings and proof – serious allegations (fraud/theft) must be clearly pleaded and proved; Master’s written endorsement – compliance with section 6(1) – validity of trustee appointments; trust deed interpretation – spouse appointment clause; procedural impropriety – reliance on annexures from unpursued contempt application impermissible; accounting orders – must be precise and enforceable.
4 October 2024
Applicant not shown to be fit and proper; respondent’s refusal to permit employment at O’Brien Inc was unreasonable and set aside.
Legal Profession — Readmission — ‘Fit and proper’ requirement under LPA — heavy onus of genuine, complete and permanent reformation; Administrative law — refusal to grant prior written consent under s 33(4)(b) LPA — constitutes administrative action reviewable under PAJA where decision is unreasonable or procedurally unfair; Procedural fairness — audi alteram partem and consideration of relevant intervening facts and mitigatory conditions; Mootness — employment issues capable of becoming academic.
1 October 2024
Convictions for kidnapping and rape upheld; prescribed life sentence affirmed as no substantial and compelling circumstances existed.
Criminal law – kidnapping and rape – evaluation of evidence as a mosaic; single‑witness cautionary rule; weight of corroborative evidence including J88; materiality of isolated contradictions; prescribed minimum sentence under s51(1) Criminal Law Amendment Act – substantial and compelling circumstances; appellate interference with sentencing discretion.
1 October 2024
Court imposed a lesser sentence for murder due to substantial and compelling circumstances despite the seriousness of domestic violence.
Criminal law – Sentencing – Murder – Substantial and compelling circumstances – Deviation from minimum sentence – Domestic/intimate partner violence – Mitigating effect of surrender and admissions – Section 51(2), Criminal Law Amendment Act 105 of 1997.
1 October 2024
September 2024
Whether the plaintiff was entitled to party-and-party costs on scale C under Rule 67A/69, or only scale B.
Rule 67A and Rule 69 – party-and-party cost scales A, B, C – prospective application from 12 April 2024; factors for scale selection: complexity, value/importance of relief; architectural/design expert evidence can render an ordinary personal-injury matter complex; absence of novel legal issues disfavors scale C; scale B awarded.
25 September 2024
Proportionality is inapplicable to forfeiture of proceeds of unlawful activities where no lawful property interest exists.
POCA – forfeiture of proceeds of crime; constitutional property protection (s25) – proceeds of unlawful activity do not attract a lawfully recognised proprietary interest; proportionality analysis inappropriate where no lawful interest exists; procedural limitation – appeal confined to issues granted in leave to appeal.
25 September 2024
Appeals struck because records partly in Afrikaans (and incomplete) lacked required English translations; magistrates must ensure English record.
Court language of record – English – Heads of Courts resolution – English as language of record for appeals. Interpretation – duty of presiding officer to provide interpreter at State expense where accused/witness not conversant with court language – failure vitiates proceedings. Record on appeal – obligation on appellant/attorney (Rule 49A) to ensure complete English record; incomplete or untranslated records justify striking appeals. Administrative directives – binding guidance in absence of Executive policy; must be implemented by magistrates.
19 September 2024
Applicant may compel respondent to produce relevant material under section 46 of the TAA, despite prescribed assessment periods.
Tax Administration Act – s46 – information gathering – peremptory power to compel production of relevant material for audit purposes. Prescription – assessment period prescribed does not preclude section 46 requests for relevant material. Constitutional right – privilege against self-incrimination (s35) does not bar compliance with administrative s46 requests in these circumstances. Administrative law – allegations of fishing expeditions and hearsay do not defeat lawful, reasonably specific s46 requests. Distinction between s46 information‑gathering and s99(2) revised‑assessment procedure.
17 September 2024
Forfeiture on divorce upheld but cannot strip a spouse of a pre-marital, validly registered co-ownership (RDP house).
Divorce — forfeiture of patrimonial benefits under s 9(1) of Divorce Act; pre-marital assets and co-ownership (RDP house) not subject to forfeiture; validity of registered transfer despite formal defects — Deeds Registries Act s 100 and registrar’s rectification power; appeals lie against substantive orders not mere reasoning.
11 September 2024
Summary judgment refused where respondents raised bona fide jurisdictional, NCA applicability and suretyship disclosure defences.
Civil procedure – summary judgment refused where bona fide defences and triable issues exist; jurisdiction – forum choice and domicilium; Rule 41A – mediation notice served; National Credit Act – large/juristic agreements outside NCA; Suretyship – duty to explain and triable issue of consent; Failure to annex pleaded documents may defeat summary judgment.
10 September 2024
Mandament van spolie not available to restore electricity disconnected for contractual non‑payment; urgency was self‑created.
Civil procedure – mandament van spolie – possession v personal/contractual rights – electricity supply under commercial contract not incident of possession (Eskom v Masinda). Urgency – Rule 6(12)(b) – self‑created urgency and duty to disclose sequence of events. Quasi‑possession – when electricity can qualify as incident of occupation (distinguished from Masinda and Harrismith).
5 September 2024
Application for leave to appeal sentence dismissed for lack of reasonable prospects and no substantial and compelling circumstances.
Criminal procedure – leave to appeal against sentence – test: reasonable prospects of success (S v Smith); sentencing discretion – substantial and compelling circumstances; holistic evaluation of mitigation and aggravation; concurrency as element of mercy.
3 September 2024
August 2024
Organ of state held in contempt for wilful non-compliance with order; suspended committal imposed subject to purge.
Civil contempt — requirements for committal: order, service, non-compliance, wilfulness/mala fides; evidential burden on respondent; organs of state duty to assist courts; late-filed notices and postponement applications in motion proceedings; suspended committal conditional on purge; attorney-and-client costs for recalcitrant conduct.
29 August 2024
Warrantless arrest upheld where officer had objectively reasonable grounds to suspect the applicant of a Schedule 1 sexual offence.
Criminal procedure – warrantless arrest – s40(1)(b) Criminal Procedure Act – requirement of reasonable suspicion on objective grounds; Evidence – identification by complainant/mother and witness vehicle description; Burden of proof – on state to justify lawfulness of arrest; Civil damages – unlawful arrest and detention claim dismissed where arrest reasonably justified despite subsequent withdrawal of charges.
27 August 2024
Special plea of prescription dismissed where defendant’s conduct and plaintiff’s incapacity supported a delictual claim against the Fund.
Prescription – special plea – where plaintiff’s real cause of action is delict for negligent handling of a statutory claim, a special plea targeting prescription of the statutory claim may be misplaced. Road Accident Fund – alleged negligent advice and failure to pursue statutory claim – acquiescence by Fund (offer and payment of medical/care costs) undermines reliance on prescription. Incapacity – severe physical impairment and possible cognitive difficulty – appointment of curator ad litem for quantum appropriate.
27 August 2024
Tender award set aside where bidder met eligibility requirements and was unlawfully disqualified without seeking clarification.
Administrative law; public procurement – meaning of “acceptable tender” – compliance ‘in all respects’ with tender specifications; procedural fairness under PAJA; duty to seek clarification and allow representations; review and setting aside of disqualification and award; remittal for de novo adjudication.
27 August 2024
Appellate court granted bail where State’s case was weak and alleged confession was unparticularised and possibly coerced.
Criminal procedure — Bail — onus and exceptional circumstances under s60(11)(a) — requirement that State show likelihoods under s60(4); Admissibility of confessions — necessity to prove prima facie admissibility; allegations of torture vitiating reliance on confession; Misclassification of charges as Schedule 6 where charge sheet lacks requisite particulars; Scope of appellate review of magistrate’s discretionary refusal of bail.
23 August 2024
Appellate court upholds rape conviction and life sentence; single child witness with cognitive impairment found credible.
Criminal law – rape of a child – single child witness with cognitive impairment – cautionary rule – proof of sexual penetration – weight of medical and corroborative evidence – sentencing – prescribed minimum life imprisonment – substantial and compelling circumstances.
22 August 2024
Urgent application improperly brought and unexplained delay justified striking matter off the roll with costs against the applicant.
Civil procedure – Urgent applications – Rule 6(12) – Applicant must justify non‑compliance with ordinary rules and explain any delay. Self‑created urgency – An applicant may not wait until normal rules cannot be applied and thereby manufacture urgency. Administrative/regulatory enforcement – Statutory regulatory body must still comply with procedural fairness when seeking urgent interdicts. Costs – Improper classification of matters as urgent may attract an adverse costs order to deter misuse of court process.
22 August 2024