High Court of South Africa Eastern Cape, Grahamstown

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565 judgments
Citation
Judgment date
October 2022
Applicants must exhaust the section 30 regulatory remedy before seeking judicial review under PAJA.
PAJA – s7(2) mandatory exhaustion of internal remedies; Electricity Regulation Act – s30 as internal remedy; administrative review – non‑exhaustion bars PAJA review; no discretion to postpone where s7(2)(b) applies; exceptional circumstances under s7(2)(c) not established.
18 October 2022
Court upheld prescribed minimum sentence for robbery; no substantial and compelling circumstances to deviate.
Criminal law – sentencing – robbery with aggravating circumstances – prescribed minimum sentence; sentencing discretion on appeal – test for interference; consideration of pre-trial custody and concurrent sentences; aggravating effect of weapon use even without physical injury.
18 October 2022
An appellate court will not disturb a prescribed-minimum murder sentence absent material misdirection or demonstrable substantial and compelling circumstances.
Criminal law – Murder – Minimum sentences under Criminal Law Amendment Act – whether substantial and compelling circumstances justify deviation from 15 years. Sentencing – appellate review – Malgas test; deference to trial court absent material misdirection. Mitigation – alleged jealousy/‘crime of passion’ and diminished responsibility must be placed on record by accused; courts will not speculate. Comparative authorities distinguished where factual bases for mitigation existed.
18 October 2022
Applicant entitled to R15,000 monthly pendente lite credit‑card payments; trust obligations cannot be enforced in Rule 43 against a non‑party.
Civil procedure – Rule 43 pendente lite relief – limits of Rule 43 where obligations are those of a trust not a party to the proceedings; Interim maintenance – entitlement to interim personal payments during divorce proceedings; Interim legal costs – assessment of reasonableness and reduction where mediation likely; Costs – usual order that costs follow main proceedings.
11 October 2022
Applicant’s urgent bid for free access to a former matrimonial home to collect belongings dismissed; items already packed and ordinary remedies available.
Family law – access to former matrimonial home barred by domestic violence interdict – applicant’s right to collect personal effects – Plascon-Evans approach to disputed facts in motion proceedings – availability of rei vindicatio or damages as ordinary remedies – costs.
11 October 2022
Applicant was refused urgent access to the former matrimonial home after the respondent had already packed and made his belongings available for collection.
Family law – Divorce – Access to former matrimonial home – Collection of personal property – Rights of access where personal belongings already packed and made available for collection – Urgent interdictory relief – Availability of alternative remedies.
11 October 2022
Failure to properly consider correctional supervision and a deficient report vitiated the sentence, requiring remittal for fresh sentencing.
Sentencing – Correctional supervision – s 276(1) – trial court must give proper consideration to correctional supervision and its possible conditions (house arrest, community service, district restriction). Sentencing – Adequacy of correctional supervision report – deficient or perfunctory reports may vitiate sentencing discretion. Sentencing – Serious violent offences – gravity and deterrence are relevant but do not absolve court from considering non-custodial options and the offender’s personal circumstances. Appeal – interference justified where trial court committed material irregularity in exercising sentencing jurisdiction.
5 October 2022
Unilateral cessation of consent‑order maintenance was wilful contempt; appeal and rescission/new‑evidence applications dismissed.
Family law – maintenance – enforcement of consent maintenance order – civil contempt proceedings – requisites: order, service/notice, non‑compliance, wilfulness and mala fides (Fakie test); consent order enforceability; rescission/new evidence applications under Rule 42 and s 19(b)/s 173 – inadmissible where evidence available earlier and no explanation; inability to pay defence – evidential burden on defaulter; appellate interference only for misdirection of fact.
4 October 2022
Arrest under s40(1)(b) was lawful; interest on delictual damages runs from judgment; cross-appeal dismissed.
Criminal Procedure Act s40(1)(b) – arrest without warrant – objective reasonable suspicion – exercise of discretion to arrest must not be arbitrary, irrational or mala fide and must be properly pleaded; continued detention – lawfulness assessed on pleaded grounds and factual evidence; delictual non-pecuniary damages assessed at date of judgment — interest runs from judgment (or a short period thereafter); appellate interference with trial court costs order limited to misdirection or absence of grounds.
4 October 2022
September 2022
Cellphone, ballistic and similar-fact evidence proved conspiracy to steal rhino horn and unlawful firearm possession.
Environmental/criminal law – Rhino poaching and theft – statutory conspiracy to steal rhino horn. Evidence – Similar-fact evidence – admissibility of cellphone tower data, prior poaching incidents and ballistic linkage. Forensic evidence – Ballistics linking weapon to prior killings as circumstantial proof. Firearms law – Unlawful possession of a large-game rifle and ammunition; common purpose and associative liability.
30 September 2022
Writ and attachment set aside where attorneys acted without valid mandate; post-dated resolution invalid and punitive costs awarded.
Civil procedure – application to set aside writ of execution and notice of attachment – authority to act for company – validity of post-dated board resolution – intervention/joinder – punitive costs (attorney and client) for counsel acting without valid mandate.
27 September 2022
Appellants failed to prove exceptional circumstances for bail in Schedule 6 armed robbery; strong prima facie case and flight risk.
Criminal procedure – Bail – Schedule 6 offence – Armed robbery with aggravating circumstances – onus to prove exceptional circumstances (s. 60(11)) – considerations in s. 60(4)–(10) – strength of State case (video, vehicle tracking, confessions) – flight risk – appeal court’s review under s. 60(5).
27 September 2022
Plaintiff proved assault and arrest by police; State held vicariously liable for officers' conduct.
Delict — assault and unlawful arrest by police; assessment of credibility and probabilities; evidentiary weight of J88 and photographs; failure to call identified witness — adverse inference; vicarious liability of State for police employees where wrongful acts sufficiently linked to employment (Rabie; K; Bazley).
20 September 2022
Municipality held vicariously liable for employee’s negligent firearm discharge causing child’s injury.
Delict – vicarious liability – employee acting within course and scope or sufficiently close link to employer’s business; Negligence – discharge of firearm – foreseeability of ricochet and risk to nearby dwellings; Causation – factual and legal causation established; Employer’s statutory/administrative failures (alternative issues unnecessary once vicarious liability established).
20 September 2022
Court found RAF 90% liable; accepted plaintiff’s spinal and foot fractures and awarded R405,520 plus s17(4)(a) undertaking.
Road Accident Fund – liability and causation – whether collision caused fractures and spinal injuries – balance of probabilities. Effect of defendant’s failure to plead and to file expert reports – acceptance of plaintiff’s evidence. Application for postponement – requirements for full and frank disclosure and demonstration of good cause. Quantum – assessment of general damages for permanent impairment, chronic pain and loss of independence; application of previous awards for guidance. Section 17(4)(a) undertaking for future medical costs.
13 September 2022
Oral two-season farming contract began in late 2015; drought did not excuse performance and respondent may deduct farming and transport costs.
Contract — oral agreement for agricultural production — commencement and duration (two-season project) — vis major/supervening impossibility — requirements for impossibility — tacit terms and transport as production cost — deduction of farming expenses — alleged VAT obligation rejected.
13 September 2022
Defendant liable for unlawful assault by police; force beyond pepper spray unjustified, R100,000 awarded.
Police liability – assault by members – admissible use of force; onus on state to justify force; credibility and corroboration by independent witnesses; medical evidence of injuries; assessment of damages for contumelia and injury; costs where plaintiff abandoned part of claim.
6 September 2022
Leave to appeal dismissed; court found tender award unlawful and CIDB registration not mandatory for responsiveness.
Administrative law – review of tender award – PAJA s7(1) 180-day period; Procurement law – responsiveness v functionality – CIDB registration; Preferential procurement – misapplication of preference points renders award unlawful; Judicial review – remedy by setting aside award; Leave to appeal – test applied.
6 September 2022
1 September 2022
August 2022
Urgent interdict to stop borrow‑pit operations dismissed for self-created urgency despite competing mining‑permit claims.
Civil procedure — Urgency — self-created urgency — applicant’s delay in launching urgent application disentitles modification of rules. Interim interdict — requirements — prima facie right, irreparable harm, balance of convenience — procedural non-compliance may justify non-suit. Mining law — competing claims to mining rights and MPRDA compliance raised but not decided where urgency lacking. Administrative action — review to follow (Part B) but interim relief refused on procedural grounds.
30 August 2022
Court set aside bail refusal where magistrate wrongly penalised accused's silence and failed to properly balance s60 bail factors.
Criminal procedure — Bail — Section 60 Criminal Procedure Act — interests of justice enquiry — balancing favourable and unfavourable factors, risk of evasion and interference with witnesses. Right to silence — accused cannot be penalised at bail stage for electing not to testify or disclose defence. Charge sheets — when prosecution seeks to invoke enhanced sentencing regimes (Schedule 5), this should ordinarily be communicated in the charge sheet to ensure fair trial rights. Appellate review — misdirection on facts or law in bail refusal permits substitution of a fresh order.
30 August 2022
Committal for contempt requires an ad factum praestandum order and proof of wilfulness; municipal manager’s contempt set aside.
Local government — Structural interdict and payment agreement — Distinction between orders ad pecuniam solvendam and ad factum praestandum — Committal for contempt requires ad factum praestandum order and proof of wilfulness and mala fides beyond reasonable doubt — Responsible municipal official may be subject to mandamus on pain of committal — Provincial administrator and financial recovery plan affect implementation and accountability.
26 August 2022
A contingency-fees agreement failing to specify the attorney’s normal fees is invalid and unenforceable.
Contingency fees agreements – statutory requirement to specify 'normal fees' – s 2(1)(b) Contingency Fees Act; Court’s supervisory role when settlement accepted under ss 4(1)–(2) Road Accident Fund Act; Strict compliance required to prevent abuse; Invalid agreement entitles attorney to attorney-and-own-client fees.
23 August 2022
Review of magistrate’s rulings on search evidence, witness recall and similar‑fact evidence dismissed.
Criminal procedure — Review of magistrate’s interlocutory rulings — Admissibility of search and seizure evidence — Section 22(b)(i),(ii) Criminal Procedure Act — Consent not jurisdictional prerequisite — Recall of State witness — Similar fact evidence — Prematurity of interlocutory challenge — Procedural deficiencies in record — Condonation for late affidavit and costs.
23 August 2022
Regulator failed to prove an attorney witnessed a forged surety; application to strike off dismissed, each party to pay own costs.
Legal profession – disciplinary proceedings – allegation that an attorney witnessed a deed of suretyship containing a forged principal’s signature – burden of proof on regulator to establish offending conduct on balance of probabilities – regulator’s investigatory duties – attorney’s duty of candour – when to refer for oral evidence – sanction (striking off v suspension).
10 August 2022
Leave to appeal dismissed; Plascon-Evans applies to rescission of final consent orders and no reasonable prospects of success were shown.
Civil procedure – Rescission of consent order – Whether Plascon-Evans rule applies where rescission seeks final alteration of settlement order. Finality of judgments – Consent orders and settlement agreements incorporated into orders. Mistake and iustus error – Burden and applicability in rescission of consent orders. Interests of justice – Requirements to grant rescission and lack of authority to expand ‘good cause’. Key authorities: Storti v Nugent; Slabbert v MEC; Gangat v Akoon; Moraitis Investments v Montic Dairy.
10 August 2022
Appeal against conviction and eight-year sentence for corruption by a public prosecutor dismissed; evidence and sentence upheld.
Criminal law – Corruption by public official – Acceptance of gratification to withdraw charges – Admissibility of sting/undercover evidence (s252A) – Entrapment where agreement pre-existed police involvement. Appeal against sentence – Appellate interference only for material misdirection or shockingly inappropriate sentence (S v Malgas). Sentencing considerations – seriousness of corruption, deterrence, offender’s personal circumstances and rehabilitation.
10 August 2022
Leave to appeal dismissed: proposed amendments would create unmanageable overlapping proceedings and lacked reasonable prospects.
• Civil procedure – amendment of pleadings – deletion of "conditional" from counter-application and supplementary affidavit; • Incorporation by reference – admissibility and propriety of incorporating extensive averments from prior affidavits; • Exercise of judicial discretion – Pearson & Hutton; Whittaker v Roos; whether amendment would produce unmanageable, overlapping proceedings; • Appealability – s17(1)(a) Superior Courts Act – requirement of reasonable prospect of success.
2 August 2022
Leave to appeal refused: proposed amendment would cause overlapping, unmanageable proceedings and discretion was properly exercised.
• Civil procedure – amendment of pleadings – incorporation by reference – limits on unqualified incorporation of extensive averments. • Civil procedure – conditional counter-applications – scope and transformation into stand-alone applications. • Civil procedure – joinder and overlapping proceedings – prejudice and unmanageability from parallel proceedings between same parties. • Appellate procedure – leave to appeal under s 17(1)(a) Superior Courts Act – reasonable prospect of success; stricter test. • Judicial discretion – exercise in granting or refusing amendments; necessity to prevent injustice or undue complication. • Costs – order for two counsel not justified in complex but not exceptional litigation.
2 August 2022
A tacit contractual duty to account was implied; the trust bore the onus to prove repayment and the appeal was dismissed.
Contract – implied/tacit term – officious bystander / business efficacy tests – duty to account and debatement where purchaser pays seller’s creditors; Burden of proof – defendant who pleads repayment/discharge must prove it; Evidence – failure to call an available witness not automatically fatal; Pleading and proof – unpleaded oral agreement (novation/offset) inadmissible as it would ambush opponent.
2 August 2022
July 2022
Minor attestation pronoun error not fatal; applicants penalised with attorney-and-client costs for dilatory last‑minute postponement.
Practice — Affidavits — Attestation errors (incorrect gender pronoun) — substantial compliance and judicial discretion to admit affidavit; Costs — postponement due to litigant’s dilatory conduct — attorney-and-client (punitive) costs for wasted costs occasioned by late postponement.
28 July 2022
Refusal of PAIA access must be justified by proving disclosure would be 'unreasonable'; TOPS permit records required disclosure.
Access to information – PAIA s34(1) – meaning of 'unreasonable disclosure' of third‑party personal information – IO must assess reasonableness; not an automatic bar. PAIA and POPIA reconciled – objections under POPIA must be reasonable. Environmental/public interest – TOPS permit applications for vulnerable species acquire a social dimension; limited expectation of privacy. Burden on state to justify refusal on balance of probabilities. Order to set aside refusal and disclose records.
26 July 2022
Forfeiture under POCA requires a sufficiently close, temporally proximate evidential link proving property is proceeds or an instrumentality of crime.
POCA (ss 38, 48–57, 50, 53) – forfeiture by default; instrumentality vs proceeds of unlawful activity; evidential and temporal link required; balance of probabilities standard; constitutional limits on forfeiture.
26 July 2022
June 2022
A joint venturer must plead the factual and legal basis to enforce and accept repudiation; failure renders particulars vague and excepiable.
Contract law – joint venture as contracting party – whether a joint venturer may unilaterally accept repudiation and sue for damages without pleading basis for locus standi; Civil procedure – pleadings – Rule 18 requirement for clear, concise and particular material facts; Exception – vagueness and failure to disclose cause of action resulting in striking out with leave to amend; Co-creditors – distinction between joint and joint-and-several entitlement and need to plead basis for unilateral enforcement.
23 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