High Court of South Africa Eastern Cape, Mthatha - 2022

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52 judgments
Citation
Judgment date
December 2022
Employee contractual right to a written account and debatement of overtime cannot be denied by deferring to PAIA or internal review procedures.
* Labour law – employment contract – entitlement to written statement of account and debatement for overtime worked; contractual obligation to account. * Procedure – claim for account and debatement – requirements: right to account, contractual terms affecting amount, failure to render an account (Doyle test). * Access to information – PAIA/internal review not a prerequisite to litigating a contractual accounting claim.
13 December 2022
Court dismisses attempt to compel Premier to investigate; referral order binds the Commission, not the Premier.
* Administrative law – interpretation of court orders – referral to statutory commission v. executive discretion; * Traditional leadership law – repeal of Framework Act and commencement of Khoi‑San Act; * Section 59(2) Khoi‑San Act – discretionary power of Premier to designate investigative committee; * Section 65(2) Khoi‑San Act – saving/correspondence provision does not permit court to usurp discretion where no submission to Premier made; * Procedural – appropriate remedy is variation/amendment of order, not enforcement against non‑addressee; * Costs – unsuccessful, misdirected litigation against public office‑bearer attracts costs.
13 December 2022
Fourth applicant lacked standing; first and third disconnections lawful; application dismissed with costs against applicants.
Local government — electricity disconnection — lawfulness under Municipal credit-control policy and Electrical Installation Regulations; indigent-subsidy applications do not confer automatic entitlement pending approval; locus standi — residents' association must show authorisation or legal persona to sue; Plascon-Evans principle in motion proceedings; costs where litigation is abusive.
13 December 2022
Applicant's arrest and detention unlawful; malicious prosecution claim dismissed; R456,000 awarded for unlawful deprivation of liberty.
Unlawful arrest — s 40(1)(b) CPA — reasonable suspicion must be personally formed and based on reasonable grounds; arresting officer must consider and, where appropriate, investigate exculpatory alibi. Malicious prosecution — requires lack of reasonable and probable cause and animus; prosecutor's assessment of docket material can found reasonable and probable cause. Assessment of damages for unlawful arrest and detention — solatium, duration and conditions considered.
13 December 2022
Applicant failed to prove contempt; Rule Nisi interpreted narrowly and application dismissed with costs.
Contempt of court – requirements for contempt (existence of order, service/notice, non-compliance, wilful and mala fide) – Rule Nisi interpretation – lis pendens and discretion to stay proceedings – disputes of fact in motion proceedings requiring careful assessment.
8 December 2022
Second accused discharged for insufficient evidence; first accused must answer charges due to incriminating blood/DNA evidence.
Criminal procedure – s174 CPA – discharge at close of State case – Lubaxa standard – circumstantial evidence and forensic links (blood/DNA) may create a prima facie case; insufficiency of motive/suspicion alone warrants discharge.
2 December 2022
Applicant failed to prove authenticity of disputed liquor licence; urgent relief dismissed and respondents awarded costs.
Administrative law – Liquor licensing – Validity and authentication of disputed liquor trading licence – Plascon‑Evans application where applicant fails to dispute respondent's factual allegations – State Liability Act service requirements – purposive approach to statutory service – urgent relief burden and costs.
1 December 2022
Court granted final interdict protecting community’s site demarcation and ordered respondents to cease harassment and pay costs.
• Civil procedure – final interdict – requirements (clear right; injury or apprehension; no alternative remedy) – Setlogelo principle; • Evidence on motion – disputes of fact – Plascon-Evans and Wightman principles; • Customary/ traditional structures – joinder of traditional council – necessity requires direct and substantial interest; • Land/occupation rights – long-standing community occupation can ground protectable rights warranting injunctive relief; • Enforcement – court may authorise police assistance to sheriff.
1 December 2022
November 2022
Defendant failed to prove prescription; court refused remit for further evidence and dismissed the special plea.
Civil procedure – prescription – burden on defendant raising special plea to prove inception and completion dates and claimant’s knowledge; where facts lie within claimant’s knowledge defendant bears a reduced evidentiary burden but must still adduce evidence; parties’ agreement to separate issues must be respected; condonation under s 3 of the Act does not necessarily operate as res judicata.
29 November 2022
Condonation refused where Rule 30(2)(b) notice was defective, delays inadequately explained, and prospects of success absent.
Civil procedure – Rule 30 irregular proceedings – Requirement that a Rule 30(2)(b) notice must afford ten days to remove causes of complaint and warn of consequences – Rule 30(1) applications must be instituted within prescribed time – Condonation principles (Melane factors) – Attorney negligence and limits to relying on representatives’ delays – Prejudice and undue delay in minor child medical negligence claims.
22 November 2022
Appeal reinstated; default judgment not void ab origine, but illegal usurious interest corrected to prevailing legal rate.
Condonation — reinstatement of lapsed appeal; rescission of default judgment — Rule 49(1) (20-day rule) v Rule 49(8)/s36(1)(b) Magistrates’ Court Act; void ab origine — limited to no service/no mandate/no jurisdiction; magistrate’s discretion to accept affidavit evidence (rule 32(2)); prescribed/presiding rate of interest — illegal usurious interest corrected; costs allocation for condonation and abandoned application.
8 November 2022
October 2022
Non-compliance with court rules and delayed, uncondoned review of the Master’s appointment justified striking the application off the roll.
* Civil procedure – compliance with Uniform Rule 62 and Practice Directive – proper pagination, collation and annotation of papers required; non-compliance may justify striking matter off roll. * Administrative law – challenge to Master’s appointment of executor amounts to review under PAJA and is subject to rules against unreasonable delay and condonation. * Estates – Administration of Estates Act – appointment and removal of executors are powers of the Master; removal by court only on s54(1)(a) grounds. * Costs and sanctions – courts may sanction practitioners for persistent non-compliance, including striking matters and warning about fees.
20 October 2022
Rescission refused where applicant’s prolonged inaction and attorney negligence failed to justify setting aside dismissal.
* Civil procedure – Rescission of judgment – Uniform Rule 42(1) and common-law rescission – limits where judgment was procedurally competent and not erroneously granted. * Uniform Rule 30 – declaration of irregularity, leave to amend, and power to order dismissal if irregularity not removed. * Effect of dismissal – equivalent to absolution from the instance; plaintiff may in principle sue afresh. * Attorney negligence and client passivity – inadequate explanation for default; need for reasonable explanation and good prospects on merits for rescission.
18 October 2022
Leave to appeal refused where evidence supported conviction for assault with intent to do grievous bodily harm and sentence was appropriate.
Criminal law – Competent verdicts to murder – Assault with intent to do grievous bodily harm as competent verdict where assault forms part of actus reus of murder; common purpose liability; sufficiency of evidence without individualised identification; forensic pathology evidence; sentencing and deterrence in witchcraft‑related vigilante violence.
6 October 2022
September 2022
A mortgaged primary residence may be declared executable where debtor cannot show alternative means or disproportionate rights infringement.
* Civil procedure – Uniform Court Rule 46A – declaration of primary residence executable where mortgage bond and arrears exist; proportionality test and constitutional rights to property and housing. * Execution against mortgage security – efficacy and public confidence; refusal only where gross disproportionate infringement shown. * Suspension of execution – discretionary relief requires credible prospect of payment within reasonable time.
27 September 2022
Applicants lacked possession or clear right; interdict to prevent demolition or compel rebuilding was refused.
* Civil procedure – interim and final interdicts – requirements: prima facie/clear right, irreparable harm, balance of convenience. * Property – state land – occupation of vacant state land; absence of allocation or lawful possession. * Spoliation – mandament van spolie requires proof of prior peaceful and undisturbed possession. * Evidence – contemporaneous photographs can disprove asserted demolition or existence of structures. * PIE inapplicable where occupiers do not live on the land and are not in possession.
27 September 2022
Defendant liable for 105 days' unlawful detention; R500,000 awarded in general damages.
Unlawful arrest and detention – police liability for post-appearance detention – legal causation in remand cases – assessment of general damages for prolonged unlawful detention (105 days).
27 September 2022
The defendant unlawfully arrested, detained and shot the plaintiff; the State failed to justify the arrest or use of lethal force.
Police liability; unlawful arrest and detention — section 40(1) CPA — Schedule 1 jurisdictional requirement; use of force/private defence — necessity and proportionality; onus of proof on State; judgment at close of defendant’s case where defendant bears onus.
8 September 2022
A single breach can justify applying to operationalise a suspended sentence, but doing so prematurely risks unfair prejudice and must await finality.
Criminal procedure – Operationalisation of suspended sentence – Single breach suffices in principle, but application premature if subsequent conviction/sentence or appeal/review not finalised; proper procedure is to apply in the original suspended-sentence case after relevant milestones (S v Hoffman).
8 September 2022
Court found arrest, detention, assault and defamation by police unlawful; awarded R240,000 plus costs.
Police liability – unlawful arrest and detention – s 40(1)(b) CPA – credibility assessment of witnesses – assault supported by medical report – defamation and contumelia – quantum of damages.
4 September 2022
Applicant granted leave to amend particulars correcting location and commanding officer; amendment caused no prejudice or new cause of action.
* Civil procedure – Amendment of pleadings – Rule 28 – Delay in seeking amendment – prejudice must be shown – mala fides required to refuse. * Pleadings – Facta probanda – amendment of non-essential particulars (place and identity of commanding officer) does not introduce new cause of action. * Institution of Legal Proceedings Against Certain Organs of State Act – alleged conflict with statutory notice held without merit where facts corrected do not alter cause of action. * Prescription – amendment does not revive or create a new prescribed claim where essential cause remains unchanged.
1 September 2022
Application to review removal as headman dismissed due to res judicata and non‑compliance with PAJA time limits.
Administrative law – review – res judicata – prior dismissal of proceedings challenging same administrative decision precludes relitigation; PAJA – time limits – review launched outside 180‑day period without condonation; procedural fairness claims not addressed where preliminary objections dispose of matter.
1 September 2022
Review of headman removal dismissed for res judicata and failure to comply with PAJA time limits.
Administrative law – review of administrative decision – res judicata applies where identical decision previously challenged and dismissed; PAJA s.7 – 180‑day prescription; condonation requires adequate explanation for delay; merits of customary leadership claim not adjudicated.
1 September 2022
Refusal of bail upheld: appellant failed to show exceptional circumstances against a strong state case and risk to public peace.
Bail – s 60(4), s 60(11) and s 65 Criminal Procedure Act – exceptional circumstances – strength of state case assessed by circumstantial evidence – risk of disturbance to public peace – appellate de novo review restricted to evidence before court a quo.
1 September 2022
August 2022
Whether the applicant may evict unlawful occupants and whether the rectifying title transfer to the provincial government is valid.
* Property law – Eviction of unlawful occupiers from state-owned property; * Title rectification – validity of rectifying transfer to provincial government; * Delegation/donation of state land – chronology, registration and effect; * Administrative law – whether rectification/transfer constitutes administrative action (PAJA); * Prescription and acquisitive prescription; * Effect of spoliation orders on subsequent eviction proceedings.
23 August 2022
Court finds defendant liable for unlawful warrantless arrest and detention, awarding R95,000 plus interest and costs.
Police powers of arrest – Criminal Procedure Act s 40(1)(a) – requirements for warrantless arrest; Obstruction of justice – elements and application to speech; Freedom of expression as safeguard; Unlawful arrest/detention – damages assessment and interest.
18 August 2022
Subjective belief in witchcraft may be a substantial mitigating factor permitting departure from prescribed life sentences.
* Criminal law – Murder committed in furtherance of a common purpose – Minimum sentence under s51(1) and Part 1 of Schedule 2; * Sentencing – section 51(3)(a) substantial and compelling circumstances – subjective belief in witchcraft as mitigating factor; * Sentencing triad – consideration of seriousness, personal circumstances, deterrence and rehabilitation; * Convictions – murder, assault with intent to do grievous bodily harm, imputing witchcraft; * Sentence: effective 17 years for four murder-convicted accused; effective 5 years for accused convicted of assault and imputing witchcraft.
18 August 2022
Default judgment rescinded for failure to give required notice; applicants granted leave to file plea and each party to pay own costs.
Civil procedure – rescission of default judgment – rule 42(1)(a) – judgment erroneously sought/granted in absence of party – failure to give rule 31(5)(a) notice; condonation under rule 27 for failure to file plea – settlement negotiations and payment as good cause; costs — each party to pay own costs.
16 August 2022
Reported
High Court finds unilateral retrospective salary deductions unlawful; orders reinstatement and attorney-and-client costs.
Employment law – deductions from remuneration – Basic Conditions of Employment Act s 34 – requirement for law/agreement or fair procedure and hearing – High Court jurisdiction under s 77(3) BCEA – unlawful retrospective recovery of salary increments – declaratory relief and reinstatement ordered; costs on attorney-and-client scale.
16 August 2022
Identification assessed with caution; ballistic linkage and possession established guilt for robbery, murders and firearm offences.
* Criminal law – identification evidence – cautionary approach to eyewitness identification; credibility assessed against contemporaneous conduct and corroboration. * Forensic science – ballistic comparison – linking firearm recovered from accused to cartridge cases at crime scenes and to correctional-centre escape. * Criminal procedure – holistic assessment of circumstantial and direct evidence to determine guilt beyond reasonable doubt. * Conspiracy – merges with completed principal offence; separate conviction inappropriate when principal offence proved.
12 August 2022
Accused failed to show exceptional circumstances for bail where strong State case, prior convictions, flight and interference risks existed.
Bail — s 60(11)(a): accused facing possible life sentence must show exceptional circumstances; consideration of strength of State case, flight risk, witness interference, and prior convictions — magistrate entitled to prefer unchallenged investigating officer’s evidence — appeal against bail refusal dismissed.
10 August 2022
Applicant’s tender rejected for lacking separate indemnity certificate; court finds rejection lawful despite ambiguous wording.
* Procurement law – tender evaluation – key competencies – distinction between professional indemnity certificate and Fidelity Fund Certificate – requirement for separate indemnity cover upheld. * Administrative review – PAJA – challenge on grounds of irrationality, bias, irrelevant considerations and procedural unfairness – failure to show non‑compliance or reviewable defect. * Tender interpretation – ambiguity in bid documents – ambiguity noted but insufficient to invalidate employer's interpretation where separate requirements and scoring are evident.
2 August 2022
The respondent is vicariously liable for police omissions that caused the applicant’s loss.
Police duty of care – obligation to protect persons and property; omissions and negligence – standard of the reasonable police response; factual and legal causation – but-for and proximity analysis; vicarious liability of the State for SAPS employees; credibility assessment of witnesses; remedy – liability established, quantum to be determined.
2 August 2022
July 2022
Lease terminated; unlawful occupier evicted after PIE-compliant notice; claimed improvement lien inadequately proven.
Eviction under PIE – holding over/expiry of lease – one month’s notice sufficient; service of s4(2) notice effective despite delivery to domestic worker if occupier received and participated; ius retentionis (improvement lien) must be adequately pleaded and proved; absence of municipal relocation report not fatal where occupier is not destitute; organ of state entitled to regain control of immovable assets.
26 July 2022
Court orders extensive discovery under Rule 35(13) to examine former executor’s estate accounts and records.
Rule 35(13) — discovery in motion proceedings; exceptional circumstances where discovery may be directed; executor’s duty of uberrimae fides and obligation to account; relevance of liquidation and distribution accounts, bank statements, company documents and sale agreements; Master’s report not a substitute for discovery from a litigant.
26 July 2022
The applicant failed to prove valid acceptance of the permanent offer; leave to appeal denied under s17 'would differ' standard.
Employment law — contract formation — offer and acceptance — fixed‑term to permanent transition; requirement of written acceptance and proper delivery (annexure D6); post‑lapse indulgence and discretionary payments do not necessarily create contract; evaluation of evidence per Stellenbosch Farmers' Winery; leave to appeal threshold raised by s 17 Superior Courts Act — applicant must show another court would differ (Mont Chevaux).
26 July 2022
An unrepresented accused must be properly advised of counsel and adequately questioned under s112 or conviction will be set aside.
Criminal procedure – unrepresented accused – duty to explain right to legal representation and legal aid; Section 112(1)(b) – adequacy of questioning and requirement to cover essential elements; Section 113 – entering plea of not guilty when accused’s answers suggest defence; Contempt/contravention of protection order – necessity to prove unlawfulness and mens rea; Proof and service of protection orders; Delay in review and bail considerations.
26 July 2022
Accused convicted of robbery, three murders and firearm possession based on eyewitness ID and ballistic links; conspiracy and attempted murder failed.
* Criminal law – identification evidence – need for caution; assessing credibility and contemporaneous reporting. * Ballistics and chain of custody – firearm recovered from accused ballistically linked to cartridges at crime scene and earlier escape incident. * Unlawful possession of firearm – proven where firearm found on accused and linked to killings. * Conspiracy and premeditation – insufficient evidence; conspiracy merges with proved robbery and therefore falls away. * Attempted murder – conviction not supported where no evidence shots were fired at alleged victim.
19 July 2022
June 2022
Applicant failed to prove unlawful dispossession; he consented to police search and insurer’s possession lacked pleaded mala fides.
* Prescription/Delay – delay in launching spoliation claim and late joinder of insurer. * Property law – mandament van spolie – requirements of peaceful possession and unlawful deprivation. * Criminal Procedure Act s 22 – consent to search and seizure; lawfulness of seizure without warrant where consent or reasonable grounds exist. * National Road Traffic Act – provision on tampered VIN does not automatically oust spoliation remedy. * Joinder – insurer’s possession and lack of pleaded mala fides or nexus precludes relief against it.
21 June 2022
The accused were convicted of murder and imputing witchcraft; arson not proven; section 204 witnesses found credible.
Criminal law — murder — group assault and common purpose; imputation of witchcraft — s182 Act 9 of 1983; arson — insufficient proof; section 204 witnesses and video evidence — credibility and indemnity; medico‑legal cause of death — blunt force trauma and extensive burns.
17 June 2022
Leave to appeal refused: rescission justified by procedural/affidavit defects; SIU’s appeal notice failed Rule 49(1)(b).
* Civil procedure – rescission under Rule 42 – affidavit formalities and substantial compliance – defective affidavit and premature enrolment can justify rescission. * Civil procedure – discretion in rescission – court may exercise a discretionary power to rescind even where requirements met; must be exercised judicially (Zuma considered). * Civil procedure – mero motu setting aside – permissible where affected parties are before the court and the validity of earlier orders is squarely in issue. * Appeals – leave to appeal under s17(1)(a)(i) and (ii) Superior Courts Act – reasonable prospects and compelling circumstances required. * Appeals – Rule 49(1)(b) – grounds of appeal must be clear, succinct and identify findings challenged; non‑compliance justifies dismissal of leave to appeal. * Intervention – SIU locus standi – failure to identify errors or grounds for intervention fatal to leave to appeal.
14 June 2022
Unilateral suspension of NPO funding without due process is unlawful and must be reviewed and set aside.
* Administrative law – Section 33 Constitution – right to lawful, reasonable and procedurally fair administrative action; unilateral suspension of NPO funding; review and setting aside of administrative action. * Non‑Profit Organisations Act s3 – state duty to promote, support and enhance capacity of NPOs; duty engaged where funding withheld. * Constitutional rights – section 28 (best interests of the child) and section 29 (right to basic education) implicated where suspension adversely affects vulnerable beneficiaries. * Remedies – judicial review, setting aside of unlawful suspension and order for payment of arrear subsidies and costs.
14 June 2022
Whether a traditional leader can obtain an interdict preventing unlawful occupation of disputed communal land pending land claims.
Land law; communal/disputed land – interim relief to prevent unlawful occupation pending restitution; jurisdiction of High Court versus Land Claims Court; locus standi of traditional leader to protect communal lands; Plascon‑Evans principle in motion proceedings; requirements for final interdict (clear right, apprehension of injury, no alternative remedy); costs follow the event.
13 June 2022
May 2022
Respondent’s warrantless arrest lacked reasonable grounds; applicant awarded damages for unlawful arrest and detention.
Criminal procedure – Arrest without warrant (s 40(1)(b)) – Objective test of reasonable suspicion – Reliability of identification evidence – Unlawful detention after first appearance – Damages for unlawful arrest, detention and contumelia.
31 May 2022
Applicant failed to establish a clear right to justify a final interdict preventing entry or removal from the marital home.
Interdict – Final interdict requirements – clear right, apprehended injury, absence of alternative remedy; locus standi in relation to marital home; Rule Nisi – lapse not decided; costs following the event.
17 May 2022
Alleged promotion is an unfair labour practice; remedy must be sought under the LRA, not by declaratory relief.
* Labour law – unfair labour practice – promotion dispute – jurisdiction under the Labour Relations Act (s186(2)(a)); * Municipal employment – promotion and appointment prescripts; * Declaratory relief – absence of contractual cause of action and failure to prove valid promotion; * LRA remedy for LRA breach (Steenkamp principle).
17 May 2022
Condonation for late statutory notice denied where applicant had knowledge of the claim and delay was unexplained.
* Institution of Legal Proceedings Against Certain Organs of State Act 40 of 2002 s3 – requirement to give written notice within six months of knowledge of facts giving rise to debt; condonation under s3(4)(b). * Knowledge of cause of action – material facts (not legal conclusions) sufficient to start the notice period. * Condonation – necessity of full explanation for entire delay, prospects of success and absence of unreasonable prejudice. * Prescription – distinct from notice requirement; non‑extinction of debt does not obviate need to show good cause.
17 May 2022
Reported
Court dismissed appeal, holding internal Framework Act processes did not bar urgent declaratory and interdictory relief.
Traditional leadership – recognition of kingship – Framework Act (ss 9, 21, 25) – whether internal customary processes must be exhausted before court relief – Oudekraal principle and administrative acts – requisites for final interdict – urgency and costs (Biowatch principle).
6 May 2022
An interim rule nisi is not suspended by appeal; respondent must comply but was not immediately found in contempt due to reliance on legal advice.
* Civil contempt – elements: order, service/knowledge, non-compliance; presumption of wilfulness and mala fides – evidentiary burden on alleged contemnor. * Superior Courts Act s 18 – distinction between a ‘decision’ (final in effect) and interim/interlocutory orders; interim rule nisi not suspended pending appeal. * Urgency – contempt proceedings generally urgent but applicants must justify truncation of rule periods. * Costs – ordinary party-and-party costs appropriate where non-compliance may have stemmed from counsel’s erroneous advice. * Citation – Minister of Justice not a necessary party to civil contempt proceedings.
3 May 2022
April 2022
An employer may not withhold salary or treat a contract as terminated for unauthorised absence without notice and fair process.
Employment law – interpretation of termination clauses – clause 22(h) (unauthorised absence) does not operate as automatic termination without notice or application of HR/collective procedures; absence/leave without pay (clause 30) requires prior notice, opportunity to explain and proper accounting before salary may be withheld.
21 April 2022