High Court of South Africa Eastern Cape, Grahamstown

580 judgments
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580 judgments
Citation
Judgment date
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
Court finds municipality and officials in contempt for failing to provide statutory pension information; suspended committal ordered.
Pension Funds Act (s13A & Reg 33) – statutory duty of employer/municipality to furnish member and contribution information; Contempt of court – requisites: order, service, knowledge, non-compliance, wilfulness and mala fides; evidential burden on respondent after applicant proves order and non-compliance; Personal liability and committal – municipal officials (municipal manager and executive mayor) may be personally committed to imprisonment (suspended) for municipal non-compliance; Insufficiency of vague defences (records destroyed by fire; settlement negotiations) where information can be reconstructed or retrieved electronically; Enforcement – Sheriff and SAPS authorised to effect committal; costs on attorney-and-client scale.
22 August 2024
Applicant who bypassed court-ordered meeting must vacate residence; eviction ordered as urgent relief with costs against him.
Administrative law – interim court order requiring convening of formal meeting before admission to residence – breach of order by applicant obtaining enrolment and residence without meeting. Civil procedure – urgency – whether urgency was self-created; applicant’s conduct justified urgent relief. University/student residence – arrears and safety concerns may justify exclusion from residence pending formal process. Costs – applicant ordered to pay costs where he was architect of his own misfortune.
22 August 2024
Applicant’s material non-disclosures and misrepresentations led to dismissal; spouse entitled to decide burial arrangements.
Ex parte/urgent relief — duty of utmost good faith and full disclosure; burial rights — civil and customary marriage, cohabitation and joint will relevant to funeral decisions; locus standi to interdict burial; material non-disclosure and false allegations justify punitive costs (attorney-and-client).
22 August 2024
Court granted condonation for late s3 notices, finding no unreasonable prejudice and prescription not established on the papers.
Administrative law; Institution of Legal Proceedings Against Certain Organs of State Act 40 of 2002 s3(4) – condonation for late section 3 notice; prejudice requirement for organ of state; prescription as special plea; balancing access to courts (s34) against finality; application of Madinda, Le Roux, Shoprite and authorities on prescription.
22 August 2024
Mere assertion that a municipal official lacked authority is insufficient to rescind a consent order without proof of ultra vires conduct.
Municipal law – consent orders and settlement agreements – rescission grounds (fraud, justus error, other just cause) – proof required; legality doctrine – municipal official’s authority; MFMA budgetary constraints – distinction between compromising litigation and incurring expenditure; Turquand/indoor management rule and estoppel cannot cure ultra vires acts absent proof.
20 August 2024
Default judgment issued against a surety who raised no valid defence and only sought time to arrange a third-party sale.
Default judgment — suretyship liability — no valid defence — request for indulgence to sell co-respondent’s property insufficient to resist judgment — interest at prime +1% — costs on attorney-and-client scale.
20 August 2024
Review dismissed: Taxing Mistress properly required a composite bill; out‑of‑town attorney costs not justified.
Taxation of costs – recoverability of fees for primary out‑of‑town attorney and correspondent at seat of court – Rule 70(8) – discretion of Taxing Master/Taxing Mistress and scope of review – condonation for late review; best interests of minor child.
20 August 2024
Accused convicted and sentenced to life for murder and prescribed minimum terms for aggravated robbery; no substantial and compelling circumstances found.
Criminal law – murder and robbery with aggravating circumstances – discretionary minimum sentences – application of Malgas test; admissibility of confession; sentencing factors (triad), remorse and concurrency of sentences.
14 August 2024
Acknowledgement of debt upheld: misjoinder of creditor’s agent; no misrepresentation or undue influence; claim dismissed with costs.
Civil procedure – joinder/misjoinder – necessity of a direct and substantial interest; Contract – avoidance – pre-contractual misrepresentation and negligent misstatement; Undue influence – requirements for proof; Attorney acting for client – duty to client and limits on liability to third parties; Costs – order on Scale B (Uniform Rule 69(7)).
13 August 2024
Unsigned, third‑party drafted will not admitted under s 2(3) absent evidence deceased drafted or intended it.
Wills Act s 2(3) — unsigned wills — requirement that document be drafted or executed by the deceased — instructions to drafter insufficient — intention to make will must be proved on a preponderance of probabilities — strict construction of s 2(3).
2 August 2024
July 2024
Consolidation under Uniform Rule 11 granted for convenience; no substantial prejudice, costs awarded.
Civil procedure – Uniform Rule 11 – consolidation of related applications – convenience, avoidance of duplication and conflicting judgments – no substantial prejudice required to refuse consolidation. Mandament van spolie – overlapping disputes regarding possession of leased vehicles. Costs – late filing/delay remedied by costs order (scale A under Rules 67A and 69).
30 July 2024
Plaintiff’s evidence accepted; insured driver found negligent and defendant liable for 100% of proven damages.
Road Accident Fund liability; negligent overtaking; credibility and reliability of witnesses; dishonest affidavits and driving with suspended licence; contributory negligence not established.
30 July 2024
Appeal against rape conviction and life sentence dismissed; complainant credible and no substantial and compelling circumstances found.
Criminal law – Sexual offences – Rape involving grievous bodily harm; single witness caution and credibility; medical (J88) and DNA corroboration; section 51(1) minimum life sentence; substantial and compelling circumstances assessed.
17 July 2024
Fingerprint linkage justified arrest, but unlawful delays and prosecutors' misrepresentation rendered subsequent detention unlawful.
Criminal procedure – s 40(1)(b) arrest – reasonable suspicion based on fingerprint linkage; s 50(1) and duty to bring arrested person to court as soon as reasonably possible; prosecutors’ duty and liability where misrepresentation causes unjustified detention; non‑compliance with advising of constitutional rights/Standing Order G341 relates to admissibility but does not automatically vitiate an otherwise justified arrest.
16 July 2024
Leave to appeal refused: victim’s reliable, corroborated evidence and aggravating factors warranted life sentence; no reasonable prospect of success.
Criminal law – leave to appeal under s17(1)(a) Superior Courts Act – higher test of ‘would have reasonable prospect of success’; Child complainant evidence – reliability and corroboration; Minimum sentence regime – substantial and compelling circumstances required to deviate; Rape of a child by a parent – serious aggravating factor justifying life sentence.
11 July 2024
Leave to appeal granted where special pleas on irregular amendment and prescription were dismissed and appeal has reasonable prospects.
• Procedural law – amendment of pleadings – compliance with Rule 28 – when amendment gives rise to new cause of action and prescription. • Evidence – credibility findings – appellate reluctance to disturb trial court findings absent clear error. • Evidence – unsworn statements not cross‑examined – probative weight. • Leave to appeal – test of reasonable prospects of success.
9 July 2024
June 2024
Sale agreement subdividing agricultural land invalid; lessee recovers deposit and reimbursement for necessary improvements, rental non-refundable.
Subdivision of agricultural land – Sale agreement attempting subdivision invalid under Subdivision of Agricultural Land Act 70 of 1970; Lease and sale to be read together; Payments by third parties accepted as agent payments; Rental for period of occupation not refundable; Enrichment/restitution – necessary improvements to another’s land recoverable where enrichment is sine causa.
25 June 2024
Police had objectively sustainable reasonable suspicion to arrest the applicant for drug offences; assault not proved, appeal dismissed.
Criminal procedure – Arrest without warrant – s 40(1)(b) and (h) CPA – reasonable suspicion must be objectively sustainable; information from undercover members and a protected informer may justify reasonable suspicion. Search warrants – invalidity of warrant does not automatically render arrest actionable; claimant must establish unlawful arrest on pleaded grounds. Evidence – conflicting versions and credibility findings – appellate court reluctant to interfere where trial court preferred respondents on probabilities. Assault claims – onus on claimant to prove injuries caused by assault; medical records must be relied upon and, if not agreed, may be insufficient to displace police version.
25 June 2024
Leave to appeal dismissed: interim order not appealable and collateral legality challenge reserved for the substantive review.
Interlocutory appeal — appealability — interim orders and interests of justice (s16(2) Superior Courts Act); leave to appeal test (s17(1)); peremptory compliance with Rule 49(1)(b); scope of interim interdict — collateral/legality challenge reserved for substantive review; Rule 41A and procedural requirements; urgency and semi-urgency considerations.
20 June 2024
Rape conviction and life sentence upheld; single-witness evidence corroborated by injuries; theft appeal not entertained without leave.
Criminal law – Sexual offences – Single-witness cautionary evaluation and corroboration by J88 injuries – Consensual intercourse allegation rejected; prescribed minimum sentence upheld – Appellate jurisdiction limited where no leave to appeal on separate count.
20 June 2024
Rape conviction and life sentence upheld; complainant’s single-witness evidence found credible and prior rape justified life term.
Criminal law – Rape – Single-witness complainant – application of cautionary approach; corroborative factors (forcible entry, protection order, medico-legal injuries) – consent and submission distinguished; sentencing – minimum and life sentences – relevance of prior rape conviction and offending on parole to rehabilitation and proportionality.
20 June 2024
Child complainant’s reliable evidence and medical findings supported rape conviction; sentenced to 20 years with ancillary prohibitions.
Criminal law – Rape of a child – single child witness – application of cautionary rule and assessment of trustworthiness. Medical evidence – Intact hymen does not exclude penile penetration; genital findings may be consistent with penetration. Intoxication – unproven intoxication does not negate criminal liability. Sentencing – substantial and compelling circumstances may justify deviation from prescribed life sentence.
20 June 2024
Bail granted where state failed to prove s60(4)(a) or exceptional s60(4)(e) grounds; magistrate failed to weigh s60(9)–(10).
Criminal procedure — bail — Schedule 5 offence and s60(11)(b) onus; s60(4)(a) (public safety) and s60(4)(e) (public order) — exceptional circumstances required; limited evidential value of general community petitions and emotive testimony; duty to weigh interests under ss 60(9)–(10); appellate intervention under s65(4) where court a quo decision is wrong.
19 June 2024
Regulation 9.3.1.2 (open-space on subdivision) does not apply to the applicant’s sectional-title development; municipality’s failure to decide first SDP is reviewable.
Town-planning — Interpretation of zoning scheme — Regulation 9.3 (Provision of Open Space) read in context — Part V governs subdivision and transfer of public open space; does not apply to communal/private open space in sectional-title development. Administrative law — Failure to take decision on site development plan — Reviewable under PAJA; conclusions founded on irrelevant considerations set aside.
18 June 2024
Failure to submit mandatory three-year audited financial statements for a >R10m tender renders a bid non-responsive; review dismissed.
Administrative law – public procurement – tender responsiveness – mandatory submission of three-year audited annual financial statements for transactions exceeding R10 million (Reg 21(d) MFMA) – failure to submit renders bid non-responsive; application of Plascon-Evans where factual dispute about audited status of AFS.
13 June 2024
Convictions obtained after procedural confusion and without proper interpretation set aside; trial remitted and legal aid/interpreter ordered.
Criminal procedure – special review under s 304(4) – convictions and sentences set aside where prior plea of not guilty pending and administrative error (misplaced charge sheet/duplicate) caused re‑pleading; necessity of legal representation and language interpreter to ensure fair trial.
13 June 2024
Magistrate’s failure to consider appellant’s personal circumstances and allow rebuttal on witness intimidation warranted remittal for rehearing.
Bail — Schedule 5 offence — onus on accused under s 60(11)(b) — magistrate’s duty to consider all relevant factors including personal circumstances and interests of minor children — duty to permit rebuttal of allegations of witness intimidation where conflicts exist — limited appellate review under s 65(4) — remedy by remittal for rehearing.
12 June 2024
Appeal allowed: trial court materially misdirected itself and State failed to prove non-consent and accused's awareness beyond reasonable doubt.
Criminal law — Sexual offences — Rape under s 3 of Sexual Offences Act — Consent and withdrawal of consent; knowledge/intention of accused; single-witness credibility; effect of alcohol and prescribed medication on consent and memory; appellate review for material misdirection; standard of proof beyond reasonable doubt.
11 June 2024
Prolonged pre‑trial detention and insufficiently corroborated state evidence justified bail under Schedule 5, subject to conditions.
Criminal procedure – Bail appeal under s65(4) CPA – Schedule 5 offences and onus under s60(11)(b) – Weight of State evidence and prolonged pre-trial detention – Interests of justice and appropriate bail conditions.
11 June 2024
Conviction for assault with intent to do grievous bodily harm set aside where intent not established; substituted with common assault and a suspended fine.
Criminal law – Assault with intent to do grievous bodily harm – Element of intent to inflict grievous bodily harm must be proved or admitted – Where not established, competent verdict of common assault applies – Review court may substitute conviction and sentence and antedate sentence.
11 June 2024
May 2024
Plaintiff may recover past medical expenses from the RAF despite medical scheme payment; affidavit evidence admitted under Rule 38(2).
Civil procedure – Rule 38(2) – admission of affidavit evidence by agreement where no cross‑examination intended; Damages – recovery of past hospital and medical expenses – medical scheme payment treated as res inter alios acta; RAF remains primarily liable; subrogation/undertaking issues between insured and medical scheme are separate; costs awarded including counsel on Scale B and expert consultation costs.
30 May 2024
Default judgment rescinded where service at registered address was defective and a bona fide defence was sufficiently pleaded.
Service — Magistrates’ Court Rule 9(3)(e) — affixing process to principal door — return of service must show process came to attention of company; defective service where return indicates attachment to unrelated premises. Rescission — section 36(1)(a) and rule 49(1)/(3) — applicant must show good cause and set out grounds of defence; affidavits not subject to pleading formalities; rescission appropriate where service invalid and bona fide defence proffered.
24 May 2024
Minor omissions in particulars of claim did not render pleading vague or prejudicial; exception dismissed under Rule 23.
Exception — Uniform Rule 23 — vagueness and embarrassment — particulars of claim — requirement of particularity (Rule 18) — MFMA s176(2) liability of municipal official — minor obscurities curable by further particulars — prejudice required to uphold exception.
24 May 2024
Accomplice evidence and corroborative material established common‑purpose liability for murder; prescribed minimum sentences imposed.
Criminal law – accomplice evidence and cautionary rule – corroboration and evaluation; doctrine of common purpose; application of minimum sentences under CLAA; murder, kidnapping and robbery with aggravating circumstances.
24 May 2024
Applicant’s self-created delay and failure to follow PAIA/Rule 53 justified striking the urgent application and ordering wasted costs.
Administrative law – urgent review proceedings – applicant must establish true urgency and explain delay; self-created urgency defeats urgent relief. Procedure – Promotion of Access to Information Act (PAIA) and Rule 53 identified as proper routes to obtain tender records rather than immediate urgent court process. Interim interdict – court may refuse to entertain merits where urgency is self-created and respondent is prejudiced by late service. Tender law – administrative capturing errors may be accepted where tender documents consistently reflect correct figures.
24 May 2024
Plaintiff’s contradictory, uncorroborated evidence failed to establish a prima facie case; absolution granted with costs.
Civil procedure – absolution from the instance – test for absolution; police liability – alleged shooting by SAPS; credibility and corroboration – contradictions, absence of hospital records and witnesses; prima facie case required to oppose absolution.
22 May 2024
Whether a clause described as "rental" created a lease caught by SALA; absolution refused.
Contractual interpretation — Endumeni approach (text, context, purpose) — Whether MSMA and addendum constituted a lease or a joint venture — Subdivision of Agricultural Land Act 70 of 1970 s 3(d) — statutory illegality and onus to prove compliance — absolution from the instance — evidential threshold for refusing absolution.
21 May 2024
Employee failed to prove contractual penalty was disproportionate; employer entitled to full contractual penalty with interest and costs.
Contract — post‑employment restraint and penalty clause — Conventional Penalties Act s 3 — onus on penalty debtor to prove disproportionality; employment law — protection of employer’s trade connections and customer goodwill; civil procedure — inappropriateness of absolution where defendant bears onus of proof.
7 May 2024
Conviction overturned where poor visibility, unreliable eyewitness evidence and inconclusive CCTV raised reasonable doubt about the appellant's guilt.
Criminal law – murder – evaluation of eyewitness evidence and CCTV – poor visibility and fast-moving scene – Van der Meyden/Chabalala test – reasonable doubt – unsafe conviction set aside.
7 May 2024
Urgent application to suspend liquidation dismissed for self-created urgency, lack of prima facie success and abuse of process.
Company law – Winding-up – stay/suspension under Rule 45A – need to show clear or prima facie right and well‑grounded apprehension of irreparable harm; Rescission of winding‑up order – s354 Companies Act/common law rescission – requires exceptional circumstances, reasonable explanation for not opposing, and prima facie prospect of success (including solvency); Urgency – self-created urgency and prejudice; Abuse of process – punitive costs.
7 May 2024