High Court of South Africa Eastern Cape, Grahamstown

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581 judgments
Citation
Judgment date
June 2022
Court ordered interim bilingual educator appointments and back-pay pending post-establishment review to protect learners' education.
Urgency; children's best interests and right to basic education; interim relief converting departmental undertakings into court orders; limits on court-ordered appointments where post-provision norms constrain permanent posts; remedial temporary appointments and retrospective pay pending review.
23 June 2022
An urgent interdict seeking the same relief as a set-down main application was struck off as an abuse of process for non-compliance with urgency rules.
Civil procedure – Urgent applications – interlocutory interdict – whether urgency established – compliance with Rule 6 required. Abuse of process – bringing separate urgent application to obtain same relief as pending main application – unjustly 'jumping the queue'. Relief struck off the roll with costs where applicant failed to show urgency and comply with urgency rules.
21 June 2022
State cannot preclude attachment of departmental PMG funds; variation of final medico‑legal judgments requires trial evidence; applicants’ relief dismissed.
• Public finance and execution – State Liability Act and Uniform Rule 45(8) – attachment of right to credit balance in PMG account is permissible; PMG not immune under s 226. • Interim relief and stays – requirements for interim interdict; balance of convenience and prima facie right – applicants (state) failed. • Finality of judgments – once‑and‑for‑all rule; variation of final orders substantive and requires trial evidence; development of common law for instalments possible but must be litigated. • PFMA duties – accounting officer and treasury obligations to budget for known/contingent liabilities; potential financial misconduct and referral under s 86 PFMA.
21 June 2022
Court found intoxication and first‑offender status substantial and compelling to avoid life sentence for double rape of elderly victim.
Criminal law – Sentencing – Minimum Sentences Act s 51(1) and Part I Schedule 2 – rape of an older person and multiple rapes engaging prescribed life sentence – whether rape involved grievous bodily harm – substantial and compelling circumstances – intoxication and first‑offender status as mitigation – concurrent sentences.
15 June 2022
Court set aside tender awards for unlawful disqualification and misapplication of the PPPFA, suspending relief 30 days to protect ongoing projects.
Administrative law – PAJA – commencement of 180‑day period; Municipal procurement – applicability of s62 MSA; Tender law – vagueness of tender requirements (CIDB proof) and responsiveness; Preferential procurement – PPPFA requires price to be included; Remedy – unlawful awards void ab initio but suspension permitted to protect public interest.
14 June 2022
Lis alibi pendens did not bar adjudication of undisputed contractual interest and costs after capital sums were paid.
Civil procedure – lis alibi pendens – elements proven but discretion to proceed may be exercised where justice and convenience so require Contract – entitlement to contractual interest on overdue payments; interest calculation undisputed Costs – bare denial insufficient to resist award of costs Constitutional right of access to courts (s 34) and balance of convenience relevant to exercise of discretion
10 June 2022
Vehicle and trailer were instrumentalities of stock theft but forfeiture was disproportionate because the incident was remote from POCA’s core objectives.
POCA – instrumentality of an offence – property must play a reasonably direct, functional role in commission of offence to qualify as instrumentality. Forfeiture – s50 – balance of probabilities required that property be instrumentality, but separate proportionality analysis under s25 Constitution is mandatory. Proportionality – applicant bears onus to show forfeiture advances POCA’s purpose of combating organised crime; ordinary crime remote from POCA’s core may render forfeiture disproportionate. Innocent owner/mitigating factors – owner’s livelihood and child’s best interests relevant to proportionality enquiry.
10 June 2022
Whether the contemnor has purged civil contempt, appropriate suspension of sentence, striking out offensive affidavit material and dismissing recusal.
Contempt of court — civil contempt; purging contempt by substantive compliance; coercive suspended sentence; balancing vindication of court authority and right to liberty; striking out offensive, irrelevant and racially‑tinged allegations in affidavits; recusal applications and the right to legal representation; attorney‑and‑client costs including two counsel.
7 June 2022
No timely application to be heard on costs; Biowatch and s32 NEMA did not excuse unsuccessful, speculative urgent environmental application.
Costs — reconsideration of costs order — Estate Garlick exception requires timely formal application to be heard on costs where costs not argued; mere correspondence insufficient. Procedural law — functus officio. Environmental law — Biowatch principle does not automatically preclude costs in interlocutory environmental applications; s 32(2) NEMA allows withholding costs where applicants acted reasonably. Leave to appeal — s 17 Superior Courts Act; no reasonable prospects or compelling reasons to appeal costs order.
7 June 2022
Court finds error in magistrate's classification of fraud charge, orders bail with conditions based on appellant’s personal circumstances.
Criminal Procedure – Bail application – classification of offence under the correct schedule – Onus of proof for bail – Consideration of personal circumstances in bail application.
7 June 2022
Attempted overreach by attorney via defective contingency-fee and excessive billing rendered him unfit to practise; suspended for two years.
Contingency-fee agreements — overreaching and excessive billing; professional misconduct — fitness to practise; suspension versus striking off; failure to comply with court directions; disparaging communications as aggravating factor; re-entry by substantive application.
7 June 2022
Whether respondent’s injuries were COIDA occupational injuries, excluding RAF liability and leaving the applicant liable.
COIDA – occupational injury – "arising out of and in the course of" employment; RAF Act ss 17, 19, 21 – substitution of Fund for identified wrongdoers; interplay between COIDA and RAF; concurrent wrongdoers and in solidum liability; s22(4) deeming and employer culpability.
7 June 2022
Claim dismissed as prescribed; plaintiff knew joint estate assets precluding misrepresentation and undue influence claims.
Family Law – Divorce Settlement – Misrepresentation and Undue Influence – Applicability of Prescription Act – Knowledge of Facts for Prescribing Debts.
7 June 2022
The court found a bare fraud charge was Schedule 1, the state failed to show s60(4) risks, and bail was granted with strict conditions.
Criminal procedure – Bail – Classification of offence on charge sheet – Simple allegation of fraud without particulars amounts to Schedule 1 offence. Right to fair trial – Accused must be informed of charge particulars prior to bail hearing; no trial by ambush. Bail – Onus – Where offence is Schedule 1, state must show interests of justice preclude release; state failed to do so where evidence was speculative. s 60(4) CPA – Grounds for refusing bail (danger to public, flight risk, intimidation, undermining justice, public order) require probative evidence, not conjecture. Bail conditions – Court may impose stringent conditions (deposit, residence, reporting, travel notifications, passport restriction).
7 June 2022
Rescission refused: applicants gave unreasonable explanations, lacked a bona fide defence, and non-receipt of s129 notices was not a defence.
Rescission of default summary judgment — requirements: reasonable explanation for default; bona fides; prima facie defence — non-receipt of s129 notices is not per se defence where notices properly dispatched — bare denials and unsupported payment claims insufficient — dismissals with costs on attorney-and-client scale.
3 June 2022
May 2022
Default judgment rescinded under rule 31(2)(b) because defendant showed a bona fide defence under s17(1)(e) of the Rates Act.
Civil procedure – rescission of default judgment – distinction between rule 42(1)(a) (erroneously granted orders) and rule 31(2)(b) (good cause) – requirements for rescission under rule 31(2)(b): explanation for default, bona fides and bona fide defence with prospects of success. Municipal law – Municipal Property Rates Act s17(1)(e) – exclusion from rates of parts of national parks not developed or used for commercial, business, agricultural or residential purposes. Intergovernmental Relations Framework Act defence raised but not decided as unnecessary.
31 May 2022
Application to set aside preservation orders dismissed: errors were inadvertent, audit report inadmissible, UIF interest and proceedings established.
Prevention of Organised Crime Act – preservation orders – reconsideration – alleged lack of uberrima fides; admissibility of audit report; UIF’s interest in preserved funds; compliance with court’s order to institute action/arbitration; interpretation and purpose of TERS directive and MOA.
31 May 2022
Appellant's challenge to MEC removal rendered moot by elections, though the MEC likely lacked the required task-team recommendations.
Local government — Code of Conduct for Councillors (Schedule 1, item 14) — MEC powers to investigate, suspend or remove councillors — requirement to act on task-team recommendations — principle of legality and PAJA review — motion proceedings: burden of proof and Plascon-Evans rule — mootness and justiciability under s16(2)(a) of the Superior Courts Act — costs where appeal becomes moot.
31 May 2022
Appeal against rape conviction and life sentence for raping a 12‑year‑old dismissed; evidence and sentence upheld.
Criminal law – Rape of a minor – single‑witness evidence corroborated by pregnancy and third‑party evidence – conviction upheld. Criminal law – Knowledge of complainant’s age – circumstantial indicators (school uniform, relationship with father, appellant’s own daughter) relevant to credibility. Criminal procedure – Delay in reporting sexual assault – delay not necessarily fatal where reasonable explanation and corroboration exist. Sentencing – Zinn triad applied; life imprisonment for repeated rape of a 12‑year‑old resulting in pregnancy not disturbingly inappropriate.
31 May 2022
Conviction for rape of a minor upheld; life sentence reduced to 15 years due to substantial and compelling circumstances.
Criminal law – Sexual offences – Rape of a minor – Conviction supported by complainant’s evidence and uncontested medical evidence of anal penetration; corroboration and credibility considerations. Sentencing – Minimum sentences – Life imprisonment found disproportionate where substantial and compelling circumstances exist (first offender; breadwinner); appellate interference appropriate where trial court materially misdirected. Procedure – Court may condone non‑compliance with time limits in the interests of justice.
31 May 2022
Final consent divorce order cannot be rescinded for unilateral mistake or mere negligence; fraud or justus error not proved.
Family law – Consent orders – Rescission/variation of consent order incorporating settlement: applicability of Plascon‑Evans where relief is final; Rule 42(1)(c) (common mistake) inapplicable absent mutual mistake; rescission at common law limited to fraud or exceptional justus error; unilateral mistake/negligence insufficient; interests of justice/public policy do not permit setting aside where legal thresholds unmet.
17 May 2022
Interim interdict granted: prima facie Clicks is a "supermarket" under the restrictive 2009 agreement and building plans lack valid municipal approval.
Interim interdict – urgency – disclosure of true extent of intended development and promptness of applicants’ steps. Contractual interpretation – whether a Clicks store constitutes a "supermarket" selling foods and household goods under a restrictive clause. Administrative law/building control – municipal approval required in writing; building control officer may only recommend, not grant approval under the National Building Regulations and Building Standards Act. Land-use compliance – alleged non-compliance with Integrated Land Use Scheme (parking). Competition defence and non-joinder of former tenant not finally decided on interim application.
17 May 2022
Selection process breached administrative-justice and procurement standards, but interim interdict was refused; review remedy retained.
Administrative law – procurement – decentralised post-panel selection – RFP and panel contract contemplated selection interviews; selection must still meet section 217(1) standards and PAJA; Treasury Regulation 16A6.6 does not permit departure from constitutional procurement principles; failure to use objective criteria and stopping of deliberation recordings undermines procedural fairness.
17 May 2022
An amendment that increases a claim beyond the magistrate's monetary limit ousts that court's jurisdiction.
Magistrates' Courts Act s29 - monetary jurisdiction; amendment increasing claim beyond jurisdiction. Special plea to jurisdiction - competency after amendment to pleadings that increases claim. Section 37(2) incidental jurisdiction inapplicable where an indivisible claim partly exceeds jurisdiction. Section 39 deduction unavailable where defendant admits only a percentage apportionment (not a specific amount). Apportionment of negligence applies to proven quantum, not to unproven pleaded sums.
17 May 2022
Court found substantial and compelling circumstances to avoid life sentence for murder during aggravated robbery, imposing lengthy determinate terms.
Criminal law – Minimum Sentences Act – murder committed in course of robbery with aggravating circumstances – assessment of substantial and compelling circumstances – weight of guilty plea, remorse, lesser/unarmed role, first offender status – concurrency of sentences; immigration offence sentence.
12 May 2022
Life sentence for rape of an older person upheld; omission to specify Part I(b)(iA) in the charge did not breach fair-trial rights.
Criminal law – Mandatory minimum sentence – section 51(1) Criminal Law Amendment Act – Rape of an older person (Part I(b)(iA) Schedule 2) – Requirement to specify minimum-sentence reliance in the charge – Fair-trial rights – Substantial and compelling circumstances – Appellate review of sentence.
10 May 2022
Condonation granted; arrest unlawful for failure to exercise discretion — damages awarded for six-hour detention.
Criminal procedure — Warrantless arrest under s 40(1)(b) — Discretion to arrest — Police must consider less invasive means and exercise discretion rationally; failure to investigate or to seek explanation can render arrest unlawful; condonation and reinstatement of lapsed civil appeals may be granted where good cause shown.
3 May 2022
Appellate court upheld assault claim, finding magistrate misapplied pleading and evidence rules, awarding damages and costs.
Delict — Assault (actio iniuriarum) — Material facts in pleadings — oral evidence describing being forced to lie down at gunpoint falls within pleaded cause of action; variance not fatal. Civil procedure — Pleadings (Magistrates’ Court Rule 6(4)-(5)) — denial without particulars/dependent evidence (AVL) insufficient; courts should determine real issues where no prejudice arises. Evaluation of evidence — Appellate review where trial court misconstrues pleadings or misapplies credibility principles. Remedies — Appeal court may substitute award on quantum where remittal would be unjust.
3 May 2022
Applicant’s warrantless arrest unlawful; damages increased to R40,000 and costs awarded.
Domestic Violence Act s 8(4)(b) & s 8(5) – warrantless arrest; requirement of reasonable grounds and imminent harm; police discretion and duty to investigate; wrongful arrest and detention – assessment of non‑patrimonial damages; appellate review of trial credibility findings; interest on judgment.
3 May 2022
April 2022
The applicant’s inexcusable delay under PAJA and weak prospects of success justified dismissal of leave to appeal with costs.
Administrative law – PAJA s7(1) – condonation for late review applications – discretion to overlook delay remains even where constitutional/statutory illegality alleged; seriousness of breach, reasons for delay, bona fides, prospects of success and public interest are relevant factors. Civil procedure – leave to appeal – reasonable prospects of success and compelling reasons required. Public law – alleged contravention of s41 – bona fides may mitigate seriousness of alleged constitutional/statutory breach.
26 April 2022
Costs apportioned where part of urgent licence application became moot after respondents' decision; each party partly successful.
Liquor licensing; mootness of urgent application; interim relief to trade pending review; mandamus; costs follow the result; apportionment of costs where parties enjoy temporal success; withdrawal and costs tenders.
26 April 2022
Municipal rezoning, removal of restrictive conditions and plan approvals were procedurally flawed and were reviewed and remitted.
Administrative law; land use planning — SPLUMA and LUPO compliance; defective service/notice under s17(2) LUPO; failure to consider objections and give reasons; unlawful approval of building plans deviating from approved SDP; review under PAJA; remedy — set aside and remit; costs.
26 April 2022
An undertaking to maintain salary payments ended when the urgent application was struck off the roll, so the interlocutory application failed.
Interim interdicts; undertakings given at case management meetings; interpretation of undertakings (Endumeni); urgency under rule 6(12); mandatory vaccination policies and employment rights; locus standi and preservation of employment pending review.
21 April 2022
High Court granted eviction despite arbitration clause because arbitration concerned arrears, not the separate eviction issue.
Lease — cancellation for non-payment of rent; arbitration clause — does not automatically oust High Court jurisdiction; stay of court proceedings required to enforce arbitration; lis alibi pendens — inapplicable where arbitration relates only to arrears not eviction; High Court concurrent jurisdiction; ejectment granted; costs on Magistrate’s Court scale.
14 April 2022
March 2022
Application to transfer actions to East London circuit court refused: s 27 does not permit transfer to circuit courts.
Superior Courts Act s 27 – removal to "another seat" – distinction between local seats (Minister-established) and circuit courts (Judge President-established); circuit courts not "another seat" under s 27; High Court obliged to hear matters within its jurisdiction; convenience of legal representatives insufficient to warrant removal.
29 March 2022
February 2022
Freeplay credits on cashless slot machines are part of the 'drop' and taxable adjusted gross revenue under the EC Act.
Gambling law – statutory interpretation – 'drop' and 'adjusted gross revenue' – inclusion of non‑cashable promotional Freeplay credits in AGR and gambling tax; provincial taxing power and constitutional challenge under s25.
24 February 2022
Provincial department had locus standi; PIE inapplicable to commercial premises; no enrichment lien—eviction ordered with 30 days.
Eviction — State department’s locus standi to sue in its own name; PIE inapplicable where leased premises used commercially; enrichment lien rejected where lease excludes compensation and no proof of expenses or value added.
15 February 2022
December 2019
Reported
Admission of children to public schools may not be conditioned on possession of identity documents; clauses requiring such documentation are unconstitutional.
Education law; right to basic education – unconditional right of "everyone" under section 29(1)(a); Admission Policy clauses requiring birth certificates or proof of legalisation unconstitutional; administrative action and PAJA condonation; Circular 06 of 2016 set aside; Immigration Act (ss.39, 42) to be interpreted compatibly with Bill of Rights so as not to bar basic education to undocumented children; best interests of the child and equality and dignity obligations; remedies and mandamus to admit children pending documentation.
12 December 2019
April 2019
Amendment changing the alleged negligent driver did not create a new cause of action or render the claim prescribed.
Road Accident Fund Act – statutory claim against Fund as substitute for wrongdoer – identity of driver not essential to debt owed. Civil procedure – amendment of particulars of claim – whether amendment introduces new cause of action or causes prescription to operate. Prescription and condonation – interests of justice test; prejudice to respondent and prospects of success.
23 April 2019
March 2019
Joint possession of firearms requires proof of knowledge and intent; mere presence or common purpose is insufficient.
Firearms Control Act – unlawful possession – possession requires corpus and animus; joint possession (Nkosi test) requires group intent to possess via detentor and detentor’s intent to hold for group; mere presence or common purpose for other crimes insufficient; statutory presumptions under s117 not invoked.
26 March 2019
January 2019
Failure to give timely statutory notice defeated constitutional damages claims, but an opt‑in class action was certified and procedural steps ordered.
Legal Proceedings Act s 3 — statutory pre‑litigation notice for claims against organs of state — condonation requirements (no prescription, good cause, no unreasonable prejudice) — Prescription Act s 12(3) — knowledge of material facts versus legal conclusions — class action certification (opt‑in) and procedural directions — constitutional damages claim and quantification of loss.
8 January 2019
December 2018
An unrepresented accused’s trial was unfair where the magistrate refused assistance, showed hostility, and admitted procedural irregularities.
Criminal procedure – unrepresented accused – duty of presiding officer to explain procedure and evidence and to assist the undefended accused – admissibility of documents and photographs – hearsay – interruptions during cross‑examination – trial fairness – conviction set aside.
14 December 2018
Reported
Pre-sequestration surrender of trust livestock and equipment were voidable preferences under s29; no proven collusion under s31.
Insolvency — disposition wide enough to include surrender/division of livestock and delivery of movable equipment — voidable preference (s29) where made within six months of sequestration and not in ordinary course of business — collusion (s31) requires proof of concurrence/intent to defraud — special notarial bond and statutory pledge do not per se validate transactions made under insolvency pressure.
13 December 2018
November 2018
Reported
Applicant’s deliberate dishonesty in admission papers rendered him unfit to be admitted as an attorney; leave to appeal refused.
Admission to legal profession — fit and proper person inquiry — deliberate dishonesty in admission papers outweighs passage of time or disclosure of convictions; Law Society recommendation tainted if based on misleading information; condonation granted but leave to appeal refused for lack of reasonable prospects.
23 November 2018
August 2018
Applicant may not rely on an unpleaded act of insolvency; raising new legal points on heads unfair and impermissible.
Insolvency — Act of insolvency — s 8(c) — Preference of creditor; Civil procedure — Motion proceedings — applicant must fully set out case in founding affidavit; raising new legal points on heads of argument impermissible where point does not emerge on papers, facts not fully canvassed and prejudice results; Debt‑rearrangement order under NCA; factual insolvency evidence (Plascon‑Evans).
28 August 2018
July 2018
Reported
Taxing master wrongly halved counsel’s first-day trial fee; full fee allowed absent evidence of other appearance work.
Taxation of costs – discretion of taxing master – review test (only interfere if clearly wrong); Counsel’s first-day trial fee – entitlement to full fee where trial postponed/settled on day unless evidence of other appearance work; Local taxation guidelines conflicting with Uniform Rules and case law – cannot be applied rigidly; Improper factual inferences and misplaced evidentiary onus vitiate taxation; Admission of amici – institutional associations admitted, individual costs consultant refused.
31 July 2018
March 2018
Stay of execution improperly granted where arbitration could not extinguish taxed costs; appeal upheld and stay set aside.
Stay of execution – arbitration – whether arbitration could negate liability on taxed costs orders; set‑off/counterclaim – not permissible by arbitrator where terms limit inquiry to amounts owing by respondent; exercise of discretion – misdirection of fact vitiating stay; appealability – interlocutory order final in effect and appealable; condonation for late filing of heads.
27 March 2018
February 2018
Exception to particulars of claim dismissed; trustees can be personally liable and unjustified enrichment and loss were sufficiently pleaded.
Trust law – trustees’ personal liability – trustees may incur delictual liability to third parties depending on facts and breach of fiduciary duty. Unjustified enrichment – condictio ob turpem vel iniustam causam – relief may be available despite illegality where par delictum rule is relaxed. Civil procedure – exception for vagueness and embarrassment – stringent test requiring prejudice to excipient. Procurement law – allegation of unlawful procurement and alleged gratification in breach of SCM and procurement statutes.
20 February 2018
May 2017
Reported
Review court corrected a mistaken statutory conviction, set aside unlawful non-parole and administrative sentencing orders, and substituted reduced sentences.
Criminal procedure – review – erroneous statutory reference in conviction corrected on review; sentencing – section 276B non-parole periods require exceptional circumstances and opportunity to address; separation of powers – court may not direct place of detention or mandate prison rehabilitation programmes; sentencing vitiated by misdirection may be altered on review.
19 May 2017
Reported
Conviction set aside where child’s unsworn, unadmonished evidence required correction; matter remitted for proper admonishment and confirmation.
Criminal procedure — Child witness — Failure to administer oath or admonish under s164 Criminal Procedure Act 51 of 1977 — Formal inadmissibility but procedural/technical irregularity — No substantial prejudice to accused — Conviction and sentence set aside — Matter remitted for proper admonishment and confirmation of evidence (S v B principles).
16 May 2017