High Court of South Africa Eastern Cape, Grahamstown

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564 judgments
Citation
Judgment date
May 2023
Interim interdict confirmed where protest organisers admitted violent, unlawful conduct and failed to comply with Gatherings Act notice requirements.
Constitutional law – Freedom of assembly (ss 17–19) – right to peaceful, unarmed protest limited where protests become violent or criminal; Regulation of Gatherings Act – statutory written notice to local authority required; interim interdict – confirmation where admitted unlawful conduct and real threat of repetition; ex parte relief and costs – failure to notify known interested parties may reduce costs award.
23 May 2023
Applicant proved insured driver’s negligence but was 10% contributorily negligent; respondent liable for 90% of damages and costs.
* Road Accident Fund Act s17(1) – liability for bodily injury caused by driving of motor vehicle – proof of negligence required. * Apportionment of Damages Act s1 – contributory negligence and reduction of damages; apportionment permissible where plaintiff’s fault is put in issue. * Civil evidence – burden of proof on balance of probabilities; credibility and absence of contrary evidence. * Negligence – foreseeability and reasonable precautions when driving at night and in wet conditions.
23 May 2023
Refusal of absolution is interlocutory and not appealable; the costs order made was erroneous and set aside.
* Civil procedure — Absolution from the instance — Refusal to absolve is interlocutory and ordinarily not appealable. * Costs — Costs ordered on refusal of absolution ordinarily stand over until trial; erroneous costs orders influenced by wrong principles are liable to be set aside. * Malicious arrest — Distinction between unlawful arrest (burden on arrestor) and malicious arrest (onus on plaintiff) relevant to correctness of costs order. * Appeals — Condonation for late prosecution may be granted in interests of justice; merits of absolution should generally be decided by court a quo at trial.
23 May 2023
Appellate court upheld conviction and life sentence, finding credible child and medical evidence and no trial misdirection.
Criminal law – rape of a child – credibility of child complainant and single witness caution; medical corroboration of vaginal penetration; appellate review of factual findings and deference to trial court; sentencing discretion and life imprisonment where offender has prior rape and shows no remorse.
23 May 2023
Court upheld rape and kidnapping convictions; life sentence for repeat rape affirmed absent substantial and compelling circumstances.
Criminal law – Rape (repeat rape) and kidnapping – evaluation of single-witness evidence and corroboration – onus and assessment of accused’s version – mandatory minimum life sentence under s 51(1) CLAA – substantial and compelling circumstances test (Malgas/Dodo).
23 May 2023
Final protection order set aside where prohibitions and communication restrictions lacked pleaded facts or evidentiary support.
Domestic Violence Act – final protection order requires proof on a balance of probabilities; relief must be supported by pleadings and evidence; courts must not grant unpleaded relief; historic allegations without evidence of present risk do not justify protection orders; procedural requirements for postponement and sufficiency of medical certificate.
23 May 2023
Applicant’s failure to plead and attach the cession (and its conditions) defeated locus standi; summary judgment refused and costs awarded to respondent.
Summary judgment — Rule 32(2) — competency of deponent who has custody of documentation; Rule 18(6) — obligation to plead and attach cession and material conditions; Rule 32(4) — evidential limits of summary‑judgment affidavits; locus standi — cessionary must plead transfer and fulfilment of preconditions; failure to comply renders particulars excipiable and summary judgment inappropriate.
23 May 2023
Rescission of default judgment refused for lack of reasonable explanation and absence of a bona fide defence.
* Civil procedure – Rescission of default judgment – Applicant must show reasonable explanation for default and a bona fide defence. * Failure to file appearance to defend or to explain awareness of proceedings undermines rescission. * Where applicant admits indebtedness and offers no factual defence, rescission will be refused. * Court discretion exercised to dismiss rescission and award costs.
19 May 2023
Inadequate, non‑self‑contained financial disclosure defeats a costs claim; child maintenance pendente lite awarded on respondent’s evidence.
* Civil procedure – Rule 43 applications – requirement that proceedings be concise, expeditious and self-contained; avoidance of prolix affidavits and referral to separate voluminous files. * Obligation of full financial disclosure in Rule 43 affidavits – failure permits adverse inference against applicant. * Maintenance pendente lite – parents’ joint duty to support minor child; quantum and sharing of medical aid, medical expenses, schooling and extracurricular costs may be ordered where supported by evidence.
18 May 2023
Court imposed life imprisonment for rape of a ten‑year‑old stepdaughter; no substantial and compelling circumstances to reduce sentence.
* Criminal law – Rape of a child – Mandatory minimum sentence (life imprisonment) where victim under 16 and accused knew he was HIV positive and had unprotected intercourse (s51(1) Criminal Law Amendment Act). * Sentencing – Substantial and compelling circumstances – application of Malgas and assessment of personal mitigation versus overwhelming aggravating features (position of trust, familial context, physical injury, psychological harm). * Victim impact – Severe psychological trauma, family disruption; court requests investigation into counselling and psychotherapeutic support.
18 May 2023
Whether the respondent was maliciously arrested and detained and entitled to damages, interest and punitive costs.
* Delict – Malicious arrest and detention – elements: instigation, absence of reasonable and probable cause, animus iniuriandi – police vicarious liability. * Assault by police – unlawful use of force and contumelia. * Evidence – proper approach to credibility, reliability and probabilities where versions conflict. * Costs – punitive (attorney-and-client) costs and interest from date of demand for unliquidated claims.
11 May 2023
Rescission granted: applicants proved reasonable default explanation and raised prima facie defences, including triable public-policy and cession issues.
* Civil procedure – rescission of default judgment – common-law rescission – requirements: reasonable explanation for default and bona fide defence with prima facie prospects of success. * Contract law – cession and deed of settlement – whether creditor assumed duty to collect municipal payments and thus absolved debtor. * Contract law – public policy – challenge to contractual clause imposing liability for an organ of state’s non-payment (Beadica principles). * Pleading and procedure – court below misdirected by treating common-law rescission as rule 42(1) and determining merits rather than triability. * Delay – Covid-related difficulties considered in assessing reasonableness of delay.
9 May 2023
Plaintiff entitled to recover past medical expenses including amounts paid by her medical aid from the defendant.
Road Accident Fund — past medical expenses — recoverability of amounts paid by medical aid — payments by medical aid are res inter alios acta — plaintiff’s locus to claim medical-aid payments — subrogation and indemnity — stare decisis.
9 May 2023
Appeal dismissed: reliable eyewitness identification and corroboration established guilt; alibi rejected as not reasonably possibly true.
Criminal law – murder; identification evidence and corroboration; alibi – assessment of accused’s version; onus of proof – Tshiki v The State principles applied.
4 May 2023
Appeal reinstated and upheld: no valid sale concluded where altered purchase price lacked acceptance; condonation granted.
Property law – offer and acceptance – multiple offers and counter‑offers – no consensus ad idem where altered purchase price not accepted; Procedural law – appeal lapsing under Uniform Rules 49(6) and 49(7) – condonation and reinstatement appropriate where appeal has reasonable prospects of success; Alienation of Land Act s 2(1) – deed of alienation must be signed by parties or agents with written authority.
2 May 2023
April 2023
Youth and first-offender status can constitute substantial and compelling circumstances to depart from prescribed life sentence for child rape.
Criminal law – rape of a child – Minimum Sentences Act (Part I, Schedule 2) – whether substantial and compelling circumstances justify departure from life sentence; sentencing triad; victim impact; ancillary statutory consequences (sex-offender register; child protection register; firearm disqualification).
28 April 2023
Child complainant’s credible identification, supported by medical evidence, can suffice for a rape conviction despite reporting delay.
Criminal law — Rape — Identification by young child witness — Cautionary approach to child testimony; medical evidence of sexual penetration as corroboration; delay in reporting — s 59; evaluation of probabilities and rejection of accused’s inconsistent version.
28 April 2023
Appeal court substituted inadequate RAF general damages award, raising it to R1,200,000 and ordering interest from 14 days after 8 October 2021.
• Road Accident Fund – Narrative test/RAF4 – acceptance of serious injury and WPI ratings as jurisdictional basis for general damages. • Quantum – assessment of general damages – trial court discretion; appellate interference where discretion not judicially exercised or award is strikingly disparate. • Traumatic brain injury and psychological sequelae – consideration in whole person impairment and quantum. • Valuation date – general damages valued at currency values as at trial; substituted awards retrospective with interest under RAF s17(3)(a). • Costs – including costs of two counsel where appropriate.
25 April 2023
Applicant awarded damages for unlawful police search, arrest and assault; State held vicariously liable and ordered to pay costs.
Constitutional and delictual liability – unlawful search, unlawful arrest and assault by police; corroboration by J88 medical report; single‑witness evidence; absolution from instance refused; vicarious liability of State for police misconduct.
25 April 2023
A lease clause making the applicant’s certified account prima facie proof suffices to establish the respondent’s arrear rental if unchallenged.
* Contract/Lease – recovery of arrear rental – certified account as contractual prima facie proof of indebtedness – effect where certificates unchallenged. * Evidence – reconciliations and certification by finance manager sufficient to prove indebtedness on a balance of probabilities where no rebuttal. * Costs – contractual provision for attorney-and-client costs enforceable. * Interest – contractual interest clause (clause 38.1) enforceable on awarded amounts.
25 April 2023
An 8‑year‑old pedestrian was presumed doli incapax; insured driver held 100% liable for damages and costs.
Road Accident Fund – motor vehicle collision involving an eight‑year‑old pedestrian – presumption of doli incapax (7 to puberty) – scholar transport driver’s supervisory duty – contributory negligence and apportionment – insured driver negligent – 100% liability and costs.
21 April 2023
Failure to inquire about legal representation and ensure understanding of a guilty plea rendered the conviction and sentence unfair.
Criminal procedure – automatic review under s302 – unrepresented accused – duty of magistrate to inquire about legal representation and ensure understanding of plea under s112(1)(a) – conviction and sentence set aside where proceedings unfair.
21 April 2023
Unsoundness of unsworn child testimony rejected; admonishment satisfied s164 and conviction and life sentence affirmed.
* Criminal procedure – Child witness competence and admissibility – sections 162–164 Criminal Procedure Act – admonishment in lieu of oath. * Evidence – unsworn child testimony – role of intermediary; requirement is appreciation of truth vs falsehood, not abstract understanding of oath. * Corroboration – medical J88 and testimony of relatives corroborating child’s account. * Sentencing – prescribed-minimum life sentence for rape of a child; application of Zinn triad and absence of substantial and compelling circumstances.
18 April 2023
11 April 2023
Family Advocate’s inquiry limited to relocation; recent primary-caregiver determination will not be reopened absent good reason.
* Children — Best interests and paramountcy principle — Stability of placement and reluctance to reopen recent primary-caregiver determinations without good cause. * Family Advocate — Scope of inquiry — Limited to relocation and whether permanent removal is in the child’s best interests; not to revisit primary-caregiver status absent valid reasons. * Interim relief — Urgent interdict preventing relocation pending Family Advocate investigation and report. * Family law — Parenting plans, prior court orders and properly conducted Family Advocate reports carry substantial weight.
4 April 2023
Unlawful arrest/detention without malice: legal‑costs claim dismissed; R80,000 awarded for general damages.
Unlawful arrest and detention; actio iniuriarum; malice and honest belief; causation for legal costs; admissibility of evidence of detention conditions despite limited pleadings; assessment of solatium for brief but humiliating detention.
4 April 2023
March 2023
Homeowners' association constituted as a universitas is not a "juristic person" under s13(1)(e), so prescription was not delayed.
Prescription — Prescription Act 68 of 1969 s13(1)(e) — whether a home owners' association constitutes a "juristic person" for delay of prescription; interpretation of statutory "body corporate" under LUPO; unincorporated association (universitas) versus juristic person; onus to prove date debt due; effect of absence of governing‑body resolution evidence.
30 March 2023
Court ruled accused no.1’s confession and pointing out admissible and, on cumulative circumstantial evidence, convicted all three of arson and three murders.
Confession and pointing out — admissibility — voluntariness — trial within a trial; Circumstantial evidence — Blom principles — cumulative assessment; Doctrine of common purpose — liability for co-perpetrated arson and murder; Right to silence and procedural safeguards when recording confessions; Cross‑examination on confession content permissible where accused alleges police coaching or fabrication.
29 March 2023
Court awarded R2,146,575 for loss of earning capacity, applying 10% pre-morbid and 15% post-morbid contingency deductions.
* Road Accident Fund – assessment of capitalised loss of earning capacity – general contingency deductions – application of Quantum Yearbook guidance – discretion of court in fixing pre-morbid and post-morbid percentage deductions. * Evidence – parties agreed expert reports and special case – no viva voce evidence required. * Costs – successful applicant awarded party-and-party costs including counsel and specified consultation expenses; interest awarded.
28 March 2023
A circuit court qualifies as a "seat" under s27(1)(b), but applicants’ transfer to East London was refused for lack of convenience.
Superior Courts Act s27(1)(b) – statutory interpretation of "seat of the Division" – circuit courts as courts of the Division – transfer of civil proceedings for convenience – discretionary approach; requirements for removal (balance of convenience, pleadings, witness locations).
24 March 2023
Applicant’s condonation for late statutory notice refused: most claims prescribed, s12 arguments rejected, good cause and prejudice not established.
Proceedings Act s3(2)(a), s3(4)(b) – condonation for late statutory notice; Prescription Act ss12(3),12(4) – knowledge and tolling; prescription accrual for unlawful arrest, detention and malicious prosecution – discrete causes of action; good cause and prejudice assessments; evidence preservation and delay.
23 March 2023
Leave to appeal refused where applicant failed to establish section 18 exceptional circumstances and attacked reasons, not the operative order.
• Civil procedure – execution pending appeal – requirements of s18(1) Superior Courts Act – exceptional circumstances and irreparable harm • Appeals – appeal lies against the operative order, not reasons for judgment • Discretion – no discretion to grant execution absent factual establishment of s18 requirements; even if met, court must exercise discretion • Costs – unsuccessful leave to appeal application attracted costs including two counsel
23 March 2023
Lis alibi pendens upheld because the pending divorce's accrual determination substantially affects the vehicle ownership dispute.
* Civil procedure – lis alibi pendens (lis pendens) – requirements: pending litigation, same parties, same cause of action or substantially determinative issue, same subject matter. * Family law – matrimonial property – accrual system – inter-spousal donations and s 5(2) of the Matrimonial Property Act. * Discretion to stay proceedings – appellate restraint where lower court exercised discretion judicially. * Ownership dispute of asset during pending divorce – connection between accrual determination and rei vindicatio claim.
22 March 2023
Rescission refused: effective service established and no bona fide defence to set aside the default judgment.
Civil procedure – rescission of default judgment – Uniform Rule 42(1)(a) (error) and Rule 31(2)(b)/common law (good/sufficient cause); service of process – effectiveness of sheriff’s return at registered address; written contract variation clause vs alleged oral agreement; National Credit Act s129 inapplicable to juristic person; referral of sheriff’s conduct to Board for Sheriffs.
17 March 2023
A settlement agreement paying arrear salary without reserving interest or costs bars subsequent claims for those heads.
Compromise/Settlement agreement – effect as a contract – extinguishes cause of action (res judicata) unless rights reserved; Settlement negotiations – when silence in agreement implies compromise of ancillary claims (interest and costs); Review of court a quo – error in awarding interest after parties reached settlement; Costs – refusal to allow costs of two counsel where matter not complex.
14 March 2023
Leave to appeal refused: the applicant failed to show reasonable prospects; alleged defects were merits issues, not reviewable irregularities.
• Civil procedure – Leave to appeal – section 17 Superior Courts Act – reasonable prospects of success test as developed by SCA. • Judicial review v appeal – distinction between attacking result (appeal) and method (review); application to criminal proceedings. • Interim review of unterminated proceedings – scope of court’s power under section 22 of the Superior Courts Act. • Criminal procedure – sufficiency of charge sheet and particulars; requirements to inform accused of actus reus and enable defence. • Requirements for establishing gross irregularity or other compelling reasons to justify in medias res intervention.
9 March 2023
The court dismissed an application to remove trustees of an employee trust, finding no basis for automatic disqualification under the Trust Deed.
Trust law – Trust deed interpretation – qualification and removal of beneficiaries and trustees – Section 20 Trust Property Control Act – automatic disqualification – locus standi in related litigation.
7 March 2023
February 2023
Applicant entitled to further particulars about respondent’s finances and trust assets; accrual may be litigated within the divorce action.
Family law – Divorce and accrual – Accrual vests on dissolution but may be claimed and quantified in same action; rule 21(2) particulars – relevance of trust and financial particulars pre-divorce – duty of full and frank disclosure.
28 February 2023
Police lawfully arrested the plaintiff under s40(1)(h) CPA based on reasonable suspicion from discovered marijuana and flight.
Criminal procedure – Arrest without warrant – s40(1)(h) CPA – reasonable suspicion must be objectively sustainable based on specific and articulable facts (discovery of suspected drugs and flight); police discretion to arrest; onus on police to justify deprivation of liberty; credibility and probabilities in civil factual disputes; costs — two counsel not allowed where not reasonably necessary.
28 February 2023
Insufficient pleadings and evidence, and absence of undue benefit or substantial misconduct, justify refusal to order forfeiture under s9(1).
Divorce Act s9(1) – forfeiture of patrimonial benefits; two‑stage enquiry (benefit and undue benefit) per Wijker; evidentiary burden to prove nature and value of benefits; factors: duration of marriage, circumstances of breakdown, substantial misconduct; pleadings must properly plead and quantify relief sought.
24 February 2023
Disconnecting electricity at the registered owner’s request was contractual, not administrative action, so interim relief was refused.
Administrative law – PAJA and s 33 – distinction between contractual exercise of power by an organ of state and administrative action – municipality disconnecting electricity at account-holder’s instruction not administrative action; non-joinder where water disconnect attributed to district municipality; interim interdict requiring prima facie right and prospects of success.
23 February 2023
Whether the respondent proved lawful ownership and innocent-owner status to resist forfeiture under POCA.
* Prevention of Organised Crime Act (POCA) -- civil forfeiture of property used as instrumentality of crime; innocent owner exclusion (s54(8A)); locus standi under s39(3); proportionality in confiscation; costs and s57(5) funding of forfeiture-related expenses.
21 February 2023
Applicant failed to prove a material change or make full financial disclosure to warrant variation of maintenance pendente lite.
Family law – Maintenance pendente lite – Application to vary Rule 43 order under Rule 43(6) – Requirement of material change in circumstances; full and frank financial disclosure; credibility of alleged loss of income; impact of child attaining majority on maintenance obligations.
16 February 2023
Appellants unlawfully detained from 14:00 on 25 July to 12:00 on 27 July; each awarded R60,000 in damages.
* Administrative detention and processing – lawfulness and duration – detention for processing of multiple arrested persons under Covid-19 measures.* Unlawful deprivation of liberty – when detention becomes unlawful and foreseeability of court attendance.* Quantum of damages for unlawful arrest/detention – appellate interference where trial court misdirected and awards strikingly disparate.* Costs – discretionary orders in respect of abandoned claims not lightly interfered with on appeal.
8 February 2023
The appellate court increased the applicant’s general damages for humiliating unlawful arrest and detention from R10,000 to R30,000.
Unlawful arrest and detention – assessment of general damages – appellate interference where trial court misdirected or award palpably inadequate – importance of surrounding circumstances (public humiliation, arrest in pyjamas, filthy cells) – Rule 34 offers must be on record to be considered for costs.
7 February 2023
Ambiguous pre‑trial admission of drought insufficient to extinguish obligations; leave to appeal refused; counsel criticised for intemperate conduct.
Contract — Alleged vis major: ambiguous pre‑trial admission of drought does not, without clear evidence, amount to an admission that obligations were extinguished; divisibility and foreseeability arguments depend on finding objective impossibility; intemperate conduct by counsel may attract criticism and submissions for personal costs.
7 February 2023
Employee acted under superiors’ instructions and did not personally set the disciplinary prosecution in motion, so malicious prosecution claim failed.
Delict — malicious prosecution — requirement that defendant set the law in motion; vicarious liability where employee acts within course and scope of employment; distinction between initiating authority and subordinate acting under instruction; causation in malicious prosecution claims.
7 February 2023
Leave to appeal granted on quantum and costs where quantum was sustained but the court misdirected itself in exercising its costs discretion.
• Civil damages – assessment of general damages – discretion in quantum; globular awards may include contumelia. • Contumelia – may be incorporated in a single solatium award rather than made separately. • Costs – exercise of judicial discretion; seriousness of rights violations, public interest and witness conduct relevant to scale. • Leave to appeal – Superior Courts Act s 17(1) (higher threshold); s 16(2)(a) (exceptional circumstances for costs appeals). • Appeal practice – appellate deference to trial court’s factual findings; new evidence/authorities not adduced at trial weakens prospects of appeal.
6 February 2023
Forensic evidence linking a device to the respondent's home justified confirming rei vindicatio and rejecting an implausible theft claim.
Property — rei vindicatio — ownership established; possession at time of demand — forensic evidence showing device usage near respondent's residence and connection to home Wi‑Fi; disputes of fact on affidavit — bald, implausible allegations insufficient; court may reject improbable versions and decide on papers.
2 February 2023
Tender awards set aside because the procuring department unlawfully relaxed mandatory UIF certificate requirement and had no power to condone non-compliance.
Administrative law; Procurement law; PPPFA and "acceptable tender" threshold; Mandatory tender requirements (UIF certificate) — no discretion to condone; PAJA review; Doctrine of legality; Remedy — set aside awards and remit to re-tender.
2 February 2023