High Court of South Africa Eastern Cape, Grahamstown

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580 judgments
Citation
Judgment date
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
January 2023
The applicant's leave to appeal was refused: the agreement was not an incidental credit agreement under the NCA.
Civil procedure — application for leave to appeal; Contract interpretation — whether deferred payment agreement is an incidental credit agreement under the National Credit Act; Evidentiary weight — Rule 37 admission, handwritten Annexure and oral evidence on interest; No reasonable prospects of success on appeal.
31 January 2023
Trust’s challenge to the sale, veil-piercing and bond cancellation dismissed; procedural defects and factual/legal insufficiency fatal.
• Insolvency Act s31 — challenge to collusive dispositions before sequestration; limits of relief (no automatic retransfer). • Companies Act s20(9) — piercing/juristic personality: requirement of clear primary facts and unconscionable abuse. • Winding-up/vested rights — concursus creditorum and effect on post-commencement dispositions. • Plascon-Evans approach to resolving disputed factual allegations in motion proceedings. • Validity of registered transfer and mortgage bond — formalities and protection of bona fide secured creditors. • Joint trusteeship — necessity of joinder/authority for institution of proceedings.
26 January 2023
Hand-in-pocket conduct can sustain robbery but may not establish threat to inflict grievous bodily harm.
Criminal law – Robbery – elements: theft through violence or threats of immediate personal violence – threat may be by conduct or words. Aggravating circumstances – s 2(1)(b) CPA – threat to inflict grievous bodily harm must be established objectively; subjective fear alone may suffice for robbery but not necessarily for aggravating circumstance. Appeal/review – court may set aside wrongly qualified conviction and substitute appropriate conviction and sentence. Minimum Sentences Act – not applicable where aggravating circumstance not proved.
25 January 2023
An inadequately reconstructed trial record prejudiced the appellant; convictions and sentences were set aside.
Criminal procedure – incomplete or lost trial record – reconstruction of evidence – adequacy and procedural requirements (open court, participation of State and defence) – right to fair trial and effective appeal – setting aside conviction and sentence; s324(c) read with s313 of the Criminal Procedure Act; DPP discretion to prosecute de novo.
25 January 2023
Rescission refused: registered pension-fund rule binding and municipality failed to show reasonable default explanation or bona fide defence.
Pension-fund rules — rule amendments valid and binding once approved and registered by Registrar; interpretation of rule requiring employer–union agreement — does not delay effect of registered rule; rescission — Uniform Rule 42 and common-law rescission require error or reasonable explanation and bona fide defence; default judgment — party who knowingly abstains from opposing may be presumed in wilful default and not entitled to rescission; challenges to registered rule must proceed by review/tribunal where applicable.
24 January 2023
Plaintiff’s severe injuries were found consistent with a motor vehicle collision, and the Road Accident Fund held liable for proven damages.
Road Accident Fund – pedestrian struck at night – whether injuries consistent with motor vehicle collision – burden of proof and assessment on probabilities where only plaintiff gives evidence – defendant’s failure to adduce evidence – liability for unknown vehicle/driver; merits separated from quantum.
24 January 2023
Trial set aside because accused was represented by counsel without right of appearance; retrial ordered before a different court.
Criminal procedure – special review of part‑heard magistrates’ proceedings under section 173 – gross irregularity. Representation – appearance by counsel lacking right of appearance constitutes a fatal irregularity and is notionally prejudicial. Relief – setting aside part‑heard trial and ordering retrial de novo; desirability that a different court hear the retrial (parity with s324 CPA). DPP consent not required for High Court special review of such part‑heard proceedings.
24 January 2023
Court held prescribed minimum sentences appropriate; accused’s youth and guilty plea not substantial and compelling to justify departure.
Criminal law – Minimum sentencing (s51 Criminal Law Amendment Act) – applicability where accused was a minor – substantial and compelling circumstances required to depart – guilty plea as neutral where evidence is overwhelming – sentencing for multiple rapes and aggravated robbery; victim impact and deterrence emphasised.
20 January 2023
Accused's s112(2) admissions established elements of four rapes and an aggravated robbery; convicted accordingly.
Criminal law – guilty plea under s112(2) – sufficiency of admissions to establish elements of rape and robbery – lack of consent and intent – use of knife as aggravating circumstance in robbery.
19 January 2023
Interdict to stay execution of writ attaching business shares dismissed for lack of prima facie right and abuse of process.
Family law; maintenance order enforced by contempt proceedings and writ of execution – application for stay by interdict; lis pendens argument rejected; exemption claim under s65(e) Magistrates’ Courts Act ("tools and implements of trade") not established; failure of candid disclosure in motion proceedings; wrong procedure to set aside writ; abuse of process and attorney-and-client costs awarded.
12 January 2023
December 2022
Partial demolition ordered for outbuilding unlawfully encroaching building line, subject to engineer’s safety certificate.
Building law – building line encroachment – National Building Regulations – absence of proven written consent by neighbouring owner – prescription inapplicable to demolition declarations – discretionary and proportionate remedy: partial demolition subject to engineer’s certificate; costs.
15 December 2022
Execution pending appeal requires exceptional circumstances, irreparable harm to applicant and absence of irreparable harm to respondent.
Superior Courts Act s 18 – suspension pending appeal is norm – execution pending appeal is exceptional; applicant must prove (1) exceptional circumstances, (2) on a balance of probabilities irreparable harm to applicant if not executed, and (3) absence of irreparable harm to respondent if executed; mere assertions insufficient; prospects of success relevant but do not replace statutory twofold test.
14 December 2022
Applicant failed to establish a prima facie right to interim relief suspending his party suspension; application dismissed with costs.
Disciplinary law – internal party disciplinary cascade – NDCA and NEC jurisdiction; Interdictory relief – Setlogelo test applied to intra-party disciplinary suspension; Interpretation – contextual approach to ANC constitution; Interim relief – prima facie right, irreparable harm, balance of convenience; Costs – ordinary rule with allowance for two counsel in complex urgent litigation.
14 December 2022
Applicant’s urgent interdict failed: sale agreement was cancelled, urgency self-created and conduct amounted to abuse of process.
Interdict pendente lite — requirements: prima facie right, irreparable harm, absence of ordinary remedy, balance of convenience; Sale agreement cancelled — purchaser cannot claim specific performance where cancellation is undisputed; Urgency — must not be self-created; Abuse of process — repeated meritless litigation justifies punitive costs; Costs — attorney-and-own-client, taxable immediately.
13 December 2022
Rescission refused: applicants failed to prove delay explanation, service or locus standi defects, or prima facie defence.
Civil procedure — rescission under Rule 42(1) — requirements: reasonable explanation, good faith, bona fide defence with prima facie prospects — service of process and sheriff’s jurisdiction — locus standi of lessee/trust where letters of authority and lease exist — permission to occupy lapses on death.
13 December 2022
Application for rescission of an order restraining alleged unlawful occupation dismissed due to lack of a bona fide defense.
Civil Procedure – Rescission of Order – Jurisdiction of Sheriff – Locus Standi – Service of Court Process – Rule 42 of Uniform Rules.
13 December 2022
13 December 2022
Leave to appeal to the SCA granted in a review of an exploration right raising PAJA, consultation and language issues.
Administrative law — judicial review of administrative action — exploration right and seismic survey — meaningful consultation with affected communities — language and notice obligations — undue delay — PAJA ss 3 and 4 interplay — exhaustion of internal remedies — leave to appeal to Supreme Court of Appeal granted due to statutory-interpretation and public-importance considerations.
13 December 2022
Under amended rule 32, an evasive plea and unsupported oral compromise cannot defeat summary judgment for a secured loan.
Civil procedure – Summary judgment under amended rule 32 – plaintiff must engage with the plea to show defence not bona fide. Pleadings – Rule 18(5) – bald denials and evasive pleas impermissible. Defence – requirement of bona fide and good defence: full disclosure of nature, grounds and material facts. Contract – compromise/novation requires prior dispute; oral variation invalid where express non-variation clause requires written variation. Execution – ancillary rule 46A sale in execution application may be deferred pending summary judgment.
12 December 2022
Acquittal where prosecution failed to prove accused subjectively foresaw complainant’s incapacity to consent.
Sexual offences — incapacity to consent — definition of "person with a mental disability" under Sexual Offences Act; mens rea in rape — subjective foresight and honest belief in consent; inferential reasoning — only the sole reasonable inference may establish subjective foresight; testimonial competence of persons with intellectual disabilities — role of expert evidence and reasonable accommodations.
12 December 2022
Main seat of Eastern Cape High Court has concurrent jurisdiction; lis pendens failed because causes of action differ.
Civil procedure — rescission of judgment — distinction between quantification proceedings and rescission proceedings — lis pendens not established where causes of action differ. Superior Courts Act s6 — main seat (Makhanda) has concurrent jurisdiction over local seats in Eastern Cape. Jurisdiction — rescission may be heard at main seat despite judgments granted at local seat. Plea of appeal disguised as rescission — court will examine cause of action to determine genuine rescission.
6 December 2022
Court upheld a section 65A payment order, finding the appellant's life-insurance premiums may be used to satisfy respondents' judgments.
Magistrates' Court Act s65A — inquiry into financial position of judgment debtor — discretion to make just and equitable payment orders — life insurance premiums not a basic necessity and may be redirected to satisfy judgment debts — enforcement of default judgments by monthly instalments.
2 December 2022
Leave to appeal granted where reasonable prospects exist that a joint‑venturer may enforce its pro rata contractual rights independently.
Civil procedure – exception for vagueness and embarrassment – failure to plead basis to enforce rights arising from joint‑venture contract. Contract/partnership law – joint venture co‑creditor rights – whether a joint‑venturer may claim pro rata share independently. Leave to appeal – section 17(1)(a)(i) Superior Courts Act – reasonable prospects of success required.
2 December 2022
Leave to appeal granted against general damages award due to reasonable prospects of a materially higher award on appeal.
Civil procedure – leave to appeal – quantum of damages – trial court’s wide discretion in assessing general damages – appellate interference where reasonable prospects exist of materially higher award.
1 December 2022
November 2022
Attesting a forged signature in the signatory’s absence constitutes misconduct warranting suspension, though dishonesty must be proved for striking off.
Professional misconduct — attestation of signatures — witness attesting in absentia to forged signature — balance of probabilities establishes misconduct though dishonesty not proved — appropriate sanction: suspended suspension — regulator’s investigatory duties.
29 November 2022
Police who merely act on prosecutorial instructions do not necessarily 'set the law in motion' nor are they liable absent proof of malice.
Malicious prosecution — requisites: setting the law in motion, absence of reasonable and probable cause, malice, and failure of prosecution; investigating officer acting on prosecutor's instruction does not necessarily ‘set the law in motion’; withdrawal of charges/absence of prima facie case insufficient to establish malice; distinction between unlawful arrest and malicious prosecution and respective onuses.
29 November 2022
Leave to appeal granted because encroachment/expropriation issues raise compelling constitutional and public-law importance.
Leave to appeal — s 17(1) Superior Courts Act — test requires reasonable prospects of success or compelling reasons — leave granted where matter raises public importance relating to encroachment/expropriation, municipal competence and property rights; costs of leave application to be costs in appeal.
29 November 2022
A reliable DNA match can alone support conviction if, on the facts, it excludes every reasonable alternative inference.
DNA evidence — expert and circumstantial evidence; admissibility and probative value determined by chain of custody, sample quality, STR match and statistical frequency; no general requirement for corroboration; inferential reasoning under Blom; alibi assessed against totality of evidence.
29 November 2022
Board unlawfully repudiated a Fidelity Fund claim by relying on a belated time-bar after requesting further proof.
Sheriffs Act s 35, s 36(2)(a) & (b), s 36(3) — time for lodging Fidelity Fund claims; election to require proof under (b) removes reliance on (a). Administrative law — review for irrationality, ulterior purpose and failure to consider relevant considerations (PAJA s 6(2)). Requirement to exhaust remedies against sheriff (s 37) — scope and application vis-à-vis Fund claims. Conduct of statutory bodies — obligation to act fairly, assist claimants and not rely on inconsequential technicalities. Costs — punitive attorney-and-client costs where respondent’s conduct obstructs deserving claimants.
22 November 2022
Appellants held in civil contempt for refusing to pay reinstated status quo ante fuel price; appeal dismissed.
Civil contempt – standard of proof on a balance of probabilities where committal not sought; Interpretation of orders – orders must be read with the reasons to ascertain intention; Reinstatement of status quo ante in urgent relief includes price where intended by reasons; Procedural non‑compliance and condonation – lapsed appeal and refusal to reinstate; Costs – punitive attorney and client scale with costs of two counsel.
22 November 2022
Identification and accomplice evidence were unreliable; recent-possession and alibi issues meant convictions could not stand.
Criminal law – identification evidence – dock and CCTV-based identifications after significant lapse of time require caution and corroboration. Criminal procedure – section 204 accomplice discharge – irregular to discharge before conclusion of case; accomplice evidence requires close scrutiny. Evidence – doctrine of recent possession – requires proof that property found was the stolen property; absent identification, doctrine inapplicable. Criminal law – alibi – State must disprove alibi beyond reasonable doubt; failure to do so undermines conviction.
15 November 2022
Rescission granted: acceptable explanation for default and a prima facie defence as to game-count justified setting aside default judgment.
Rescission of default judgment; common law "sufficient cause" requires reasonable explanation for default and a bona fide defence with some prospect of success; wilful/default conduct relevant but not determinative; sale of property including game — dispute as to game-count (Annexure A1) can found prima facie defence; statutory permits and fencing compliance not established as prima facie defence.
8 November 2022
A magistrate’s cumulative courtroom interventions gave rise to a reasonable apprehension of bias, warranting review and retrial.
Criminal procedure — Recusal and review — Reasonable apprehension of bias — Leading/questioning by presiding magistrate potentially augmenting State case may found objective apprehension of bias under s 22(1)(b) Superior Courts Act; Review of lower court proceedings — High Court intervention justified where refusal to recuse risks grave injustice; Delay/condonation — multi‑factor enquiry, merits may outweigh delay; Relief — setting aside refusal, referral to DPP for re‑arraignment and de novo trial before another magistrate.
8 November 2022
Leave to appeal refused — no reasonable prospect another court would reach a different conclusion.
Appeal — Leave to appeal — s17(1) Superior Courts Act — test whether another court may reasonably reach a different conclusion; Procedural non-compliance — whether non-compliance excused where no prejudice — Miller v Natmed distinguished; Costs — no order where respondents did not oppose leave application.
8 November 2022