High Court of South Africa Eastern Cape, Mthatha

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390 judgments
Citation
Judgment date
November 2025
Issue estoppel and prescription bar a subsequent delictual damages claim based on the same factual matrix.
Civil procedure — res judicata and issue estoppel — same factual matrix and prior adjudication of prescription bar re-litigation; Prescription Act — commencement of prescription requires knowledge of minimum facts; continuous wrong does not postpone prescription of delictual financial losses; section 13(2) reciprocity inapplicable to delictual claims.
25 November 2025
Whether State Liability Act s2(2) and Joint Rule 23(m) apply to default proceedings against the Road Accident Fund.
Procedure — Road Accident Fund — Whether State Liability Act s2(2) applies to RAF — RAF is a juristic entity, not a "department" — Rule 23(m) (Joint Rules) applies to the State only — default judgment against RAF governed by Uniform Rule 31(4).
25 November 2025
Post‑expiry curatorship cannot interrupt RAF five‑year prescription; claim dismissed for prescription.
Road Accident Fund Act s23(1)-(3) – two‑stage prescription (3‑year lodgement; 5‑year enforcement) – curatorship suspends prescription only if it exists during statutory period – ex post appointment of curator ad litem cannot revive prescribed claim – without‑prejudice offers do not interrupt prescription – parties bound by pleadings.
20 November 2025
Applicants unlawfully re‑arrested and detained; respondent liable for damages until bail on 3 June 2019.
Criminal procedure — arrest and detention — whether police conduct on 2 May 2019 constituted arrest; lawfulness of re‑arrest on 13 May 2019; exercise of discretion and principle of legality; police failure to produce criminal profiles causing remand; causation — court appearance not a novus actus; damages for unlawful arrest and detention.
18 November 2025
Police unlawfully re‑arrested and detained plaintiffs; remand was foreseeable, so state liable and each plaintiff awarded R630,000.
Criminal procedure – Unlawful arrest and detention – Double arrest for same alleged offence – Doctrine of legality – Police duty to justify detention and to timeously obtain suspect profiles – Causation: magistrate’s remand not a novus actus where remand was foreseeable and reconciled by arresting officers – Quantum for unlawful detention.
18 November 2025
The applicant succeeded: police liable for malicious arrest; the prosecuting authority liable for malicious prosecution; magistrate not liable.
Delict — Malicious arrest and detention — requirements: instigation, absence of reasonable and probable cause, and malice; vicarious liability of police for arrest. Malicious prosecution — prosecutorial discretion; requirement of reasonable and probable cause (objective and subjective); prosecution policy and duty to secure minimum evidence (J88 medical report). Judicial acts — Magistrate’s adjudicative function not equivalent to setting the law in motion. Damages for deprivation of liberty and malicious prosecution; costs allocation.
18 November 2025
New s93ter(1) grants magistrates discretion on appointing lay assessors; no review where plea to competent verdict was voluntary.
Magistrates' Courts Act s93ter(1) (as substituted) – lay assessors – substitution confers discretion; Criminal Procedure Act s86 – amendment of charges; plea to competent verdict; review for gross irregularity.
18 November 2025
Spoliation unavailable for purely contractual personal rights to water; applicant failed to show possession-based right, so relief dismissed.
* Spoliation (mandament van spolie) – requirement of possession or a right incident to possession – personal/contractual rights to services insufficient; prior supply alone does not suffice. * Water supply – only protected by spoliation when it is an incident of possession (e.g., servitude or statutory right). * Lawful disconnection – owner’s request under municipal credit-control policy can render disconnection lawful.
13 November 2025
Regulation 50 creates a dispute-resolution mechanism, not an internal remedy under PAJA; applicant failed to show urgency and had discovery available.
* Municipal procurement – Regulation 50 (Municipal Supply Chain Management Regulations) – dispute-resolution mechanism/mediatory process, not an internal appeal under PAJA s7(2). * Administrative law – exhaustion of internal remedies – scope of "internal remedy" under PAJA. * Civil procedure – availability of discovery (Rule 35) in pending review proceedings as alternative remedy. * Urgency – requirements for urgent relief where review proceedings are pending and delay may be addressed by ordinary processes. * Role of provincial treasury – advisory/monitoring function and communication of outcomes to parties escalating objections.
13 November 2025
District court lacked jurisdiction to detain accused as State Patient and failed to conduct s77 enquiry or ensure representation.
Criminal Procedure Act s77 — Mental capacity enquiries; detention as State Patient; jurisdiction of district vs regional court in murder matters; requirement of legal representation under s77(1A) and constitutional right to counsel; review and setting aside of irregular detention order.
13 November 2025
Deed of sale unsigned as required by statute is void; respondents failed to establish rights for a final interdict.
* Alienation of Land Act s 2(1) – formal requirement that deeds of alienation be signed by parties or agents with written authority; non-compliance renders agreement void ab initio. * Alienation of Land Act s 28 – limits of saving non-compliant alienation where alienee has not fully performed and no transfer has occurred. * Interdicts – distinction between interim and final interdict tests; final interdict requires clear right, injury or reasonable apprehension, and absence of alternative remedies. * Jurisdiction – monetary and territorial jurisdiction: absent a valid contract the asserted purchase price cannot establish monetary jurisdiction; cause of action arising in court’s division confers territorial jurisdiction.
6 November 2025
A tender expires at the end of its validity period and cannot be revived absent a timeous, consensual extension by bidders.
* Public procurement – tender validity period – expiration and revival – requirement of timeous, consensual extension by all bidders.* Administrative law – notice of intention to award vs final award – notice alone does not interrupt validity absent a final award within period.* Tender law – awards made after expiry without extension are invalid.* Municipal procurement – adherence to bid evaluation and adjudication recommendations and transparent publication requirements.
6 November 2025
Arrest at scene was unlawful—community pressure and "protective custody" do not satisfy s 40(1)(b)'s reasonable-suspicion requirement.
Criminal procedure — Arrest without warrant — s 40(1)(b) CPA — onus on arrestor to show objective reasonable suspicion of Schedule 1 offence; "protective custody" or fear of mob justice not a lawful basis for arrest; deprivation of liberty occurs when person placed in police vehicle at scene; police detention until first court appearance must be justified by arrestor; unlawful arrest renders initial detention compensable.
6 November 2025
Warrantless arrest based on positive identification and medical evidence was lawful; malicious prosecution not established.
Criminal procedure — Warrantless arrest under s40(1)(b) CPA — Requirement of reasonable suspicion on reasonable grounds; identification and medical report as credible information. Malicious prosecution — Necessary elements: instigation, absence of reasonable and probable cause, malice and failure of prosecution; prosecutor’s honest belief and objective assessment of docket material. Police discretion to detain and court’s role in remand decisions. Costs follow result.
4 November 2025
October 2025
Court found no substantial and compelling circumstances to depart from minimum sentences for violent cash‑in‑transit robberies; life imprisonment imposed for murder.
* Criminal law – Sentencing – Application of Minimum Sentences Act s 51 and Schedules – whether substantial and compelling circumstances justify departure. * Sentencing – weight of prolonged pre-trial detention – not automatically substantial and compelling. * Confession and alleged remorse – insufficient without more to justify deviation from prescribed minimums. * Sentencing – role of ringleader and extreme violence as aggravating factors. * Firearms Control Act s 103 – declaration of unfitness to possess firearms.
31 October 2025
Notice served within six months of acquiring material facts; prescription defence dismissed and s 3 compliance declared.
* Civil procedure — Section 3 Legal Proceedings Against Certain Organs of the State Act — notice of intention to institute legal proceedings — requirement to serve notice within six months of debt becoming due. * Prescription — when prescription begins — creditor’s knowledge of facts giving rise to debt; creditor deemed to have such knowledge only when she had or could have acquired it by reasonable care (Links; Macleod). * Medical negligence — lay litigant’s need for expert evidence to identify cause and fault; delay attributable to awaiting expert/medical information may postpone accrual of debt. * Condonation/section 3(4) — good cause and prejudice to organ of state — short delay after acquisition of material facts and existence of hospital records weighed against prejudice.
30 October 2025
Whether driving, providing light and presence at a chase can found common-purpose murder; admissibility of confession and joint-possession issues.
Criminal law – Confession and pointing out – Admissibility under s217 CPA; Common purpose – requirements for inferring liability for murder; Joint possession of firearms – Nkosi/Makhubela test; Inferential reasoning – Blom principles; Competent verdicts – s270 CPA; Fair trial – potential conflict of interest from joint legal representation.
28 October 2025
Confession admitted but State failed to prove accused no.2 guilty of murder or firearm offences; accused discharged.
Criminal law – murder – doctrine of common purpose – mere presence, pursuit and provision of vehicle lights insufficient to establish intention to kill; confession and pointing out – admissibility under s217 CPA – held admissible; unlawful possession of firearms – requirement for joint possession (S v Nkosi; Makhubela) – State conceded against accused no.2; fair trial – potential conflict from joint legal representation noted.
28 October 2025
The appellant's rape conviction and 10-year sentence were upheld; complainant credible and delay in reporting not fatal to prosecution.
Criminal law – rape – single complainant evidence – cautionary approach; delay in reporting – s 59 Sexual Offences Amendment Act; corroboration by medical and sibling evidence; appellate review of factual findings; sentence and prescribed minimums.
24 October 2025
A municipality’s delayed self-review of a procurement decision was dismissed; contractor entitled to payment and declaratory relief.
Administrative law – state self-review and procurement – undue delay and condonation – principle of legality – balancing public interest and prejudice to innocent contractors – declaratory relief and payment for services rendered under an impugned contract.
23 October 2025
Default judgment: police liable for unlawful arrest, detention and malicious prosecution; damages and costs awarded to the applicant.
* Criminal procedure – warrantless arrest – section 40 CPA – objective test of reasonable suspicion; onus shifts to state once interference with liberty proved. * Civil liability – unlawful arrest and detention – damages as solatium and deterrence. * Malicious prosecution – initiation of criminal process without reasonable basis; vicarious liability of the state. * Civil procedure – bare denial struck as irregular; failure to amend plea — default judgment consequences. * Quantum – assessment guided by precedent; award of R140,000 (detention) and R120,000 (malicious prosecution).
23 October 2025
Court awards actuarially quantified loss of earnings for early retirement due to accident, applying a 20% contingency deduction.
• Road Accident Fund — quantification of loss of earnings — actuarial evidence persuasive but not binding — judicial discretion in applying contingencies; • Personal injury — early retirement caused by accident — vocational experts’ consensus; • Procedural — failure to comply with discovery (Rule 35) and striking out of defence relevant to quantum hearing.
23 October 2025
Applicants obtained a stay of eviction, alleging lack of service, PIE non‑compliance and improper standing.
Urgent application — intervention as parties — requirements for intervention (direct and substantial interest; bona fide triable defence) — stay/suspension of eviction order — PIE s 4(2) notice and service — standing to institute eviction (SGB vs state organ) — joinder of Department/MEC and municipality — right to housing and risk of homelessness.
23 October 2025
Magistrate unlawfully remanded a bailed person; acted without investigatory power or fair procedure; Minister vicariously liable, R360,000 awarded.
• Constitutional law — Right to freedom and security (s12(1)(a)) and dignity (s10) — unlawful/removal of liberty by magistrate; • Judicial immunity — limits where judicial officer acts mala fide or in bad faith; • Criminal procedure — cancellation of bail (s68(1)(e) & (g)) requires jurisdictional facts and information on oath; • Separation of powers — courts lack investigative powers; police/prosecutors responsible for investigations; • State liability — vicarious liability of Minister for wrongful acts of judicial officer.
21 October 2025
Postponement granted despite applicant’s self‑created delays; applicant ordered to pay costs on scale B including two counsel.
Postponement application – judicial discretion – good cause required – self‑created delay and malafides – disputed document authenticity not admitted at pre‑trial – costs against party responsible for delays (scale B, costs of specified trial dates and two counsel).
21 October 2025
Applicant failed to prove a copied will was a true copy and did not justify bypassing the original; application dismissed with costs.
Wills Act s 2(3) – acceptance of non‑compliant wills; burden to prove copy is a true copy; existence of original with third party; applicant’s duty to pursue original or compel production; ipse dixit insufficient; Estates Act s 8(4B) (duplicate originals) noted.
16 October 2025
September 2025
Contractual repudiation and lack of consensus rendered the tender cancellation a contractual remedy, not reviewable administrative action.
* Procurement/Tenders – post-award relationship – distinction between administrative action and contractual remedies; applicability of PAJA. * Contract law – formation, consensus on material terms, repudiation and anticipatory breach. * Restitution – liability for use of equipment following contract cancellation.
29 September 2025
Applicant failed to prove wilful, mala fide non‑compliance with court orders; contempt application dismissed.
Contempt of court — essential elements: existence of order; notice to alleged contemnor; non‑compliance; wilful and mala fide conduct — where committal sought proof beyond reasonable doubt; ambiguous orders (e.g. directing settlement) may be unenforceable; mere presence of counsel in court does not satisfy personal service requirement.
23 September 2025
Loss of support and funeral claims dismissed for lack of proof; R600,000 awarded for plaintiff's PTSD-related general damages.
* Delict — Wrongful death — Quantum — Proof of loss of support requires reliable evidence of deceased's earnings; informal/self-employed income demands corroboration. * Expert evidence — Industrial/actuarial reliance on unverified litigant-supplied figures undermines weight of reports. * Pleadings — Court will not grant damages (loss of earnings) on issues not pleaded. * Damages — General damages awarded for PTSD/complex bereavement; funeral and loss of support claims dismissed for lack of proof. * Costs — Successful plaintiff awarded costs, including specified expert and two counsel.
23 September 2025
Applicant lacked standing and motion proceedings were inappropriate due to genuine disputes of fact and procedural non‑compliance.
• Civil procedure – locus standi – adequacy of interest to challenge familial customary marriage on behalf of minor – standing must be direct, current and not too remote. • Motion proceedings – disputes of fact – Plascon‑Evans/Wightman principles – referral to oral evidence where disputes are genuine and far‑reaching. • Estate procedure – rule 6(9) – requirement to submit estate‑related applications to the Master and involve executors. • Customary marriage – proof by lobola letter, traditional leaders’ affidavits and family confirmations relevant to existence of marriage.
23 September 2025
Leave to appeal refused; court can order DNA testing of adults but exhumation was an undue, drastic measure.
* Civil procedure – Leave to appeal – Section 17 Superior Courts Act – reasonable prospect of success required. * Family/paternity evidence – Court power to order DNA testing of adults to establish paternity or for administration of justice. * Forensic procedure – Exhumation and DNA testing of deceased’s remains is a drastic measure implicating dignity and public morals; consider less intrusive alternatives (e.g., sibling testing). * Costs – unsuccessful leave application dismissed with costs on Scale B.
16 September 2025
Appellant’s failure to monitor and promptly deliver caused respondent’s child’s intrapartum hypoxic brain injury; appeal dismissed.
• Medical negligence – maternity care – inadequate intrapartum monitoring and failure to expedite delivery – breach of Guidelines for Maternity Care. • Causation – factual (but-for) and legal causation established for intrapartum hypoxic-ischaemic brain injury. • Evidence – admissibility and weight of medical records under s 3 Law of Evidence Amendment Act; records to be assessed as whole and weighed against oral testimony. • Expert evidence – binding effect of joint minutes and circumstances in which an expert may resile (Bee v RAF and related authorities). • Alternative causation (IUGR, nuchal cord, rapid labour) insufficiently proven to break causal link.
16 September 2025
Applicant failed to annex or prove a written right of first refusal and failed to establish the CEO’s authority; application dismissed.
Rule 18(6) URC – obligation to annex written contract relied on; condonation for non-compliance; agency and authority – requirement to plead and prove actual or apparent authority to bind statutory entities; doctrine of legality – public bodies may only exercise powers conferred by law or delegated by the board; requirements for proving existence and acceptance of contractual offers (right of first refusal).
11 September 2025
Unlawful and arbitrary police arrest and detention, with aggravating humiliation and degrading conditions, justified substantial damages for infringement of rights.
Delict – Unlawful arrest and detention – Quantum – Aggravating circumstances – Public humiliation; degrading detention conditions; arbitrary police conduct – Damages for violation of rights to liberty and dignity – Costs – Jurisdiction of court.
9 September 2025
Medical‑negligence claim had not prescribed because plaintiff acquired requisite knowledge only in August 2019.
Prescription — Prescription Act s 11(d) and s 12(3) — accrual of delictual cause of action — knowledge of identity of debtor and facts from which debt arises — onus on defendant pleading prescription — professional negligence context.
9 September 2025
Interdictory relief was refused to informal traders who failed to establish a right to trade in prohibited municipal areas.
Administrative law – interdict – informal trading – statutory regulation of street trading – right to trade under section 22 of the Constitution – locus standi – municipal enforcement of by-laws – public policy and doctrine of legality – unlawful trading in prohibited areas – interdictory relief for past versus reasonably apprehended future conduct.
5 September 2025
Court refused leave to appeal against the dismissal of a spoliation claim challenging lawful vehicle impoundment under traffic legislation.
Mandament van spolie – impoundment of motor vehicle – lawfulness of removal under National Road Traffic Act and Municipal By-Law – leave to appeal – prospects of success – pleading new grounds – Superior Court Act s17(1).
5 September 2025
A claim for loss of amenities of life on behalf of a profoundly impaired minor was dismissed as not competent in law.
Delict – Damages – General damages – Loss of amenities of life – Measure of damages – Whether unconscious or severely cognitively impaired plaintiffs can claim – Requirement of personal benefit – Stare decisis and Supreme Court of Appeal authority.
4 September 2025
Arrest lawful, but prosecutor’s improper Schedule 6 opposition caused unlawful detention; malicious prosecution not established.
Criminal procedure – warrantless arrest under s 40(1)(b) CPA – reasonable suspicion on reasonable grounds; Detention – lawfulness from arrest to first appearance; Bail scheduling – improper categorisation as Schedule 6 leading to unlawful post-appearance detention; Malicious prosecution – requirement of absence of reasonable and probable cause and malice; State liability – prosecutor liable for unlawful detention caused by prosecution decisions.
2 September 2025
Exhibiting an incorrect warrant makes an arrest unlawful; police liable only until the plaintiff’s first court appearance.
Criminal procedure – arrest on warrant – strict compliance with s39(2) (duty to inform/produce warrant) – exhibiting incorrect warrant renders arrest unlawful; Liability of State for detention – causation and remoteness – De Klerk principle; s67 (bail cancellation/forfeiture) and effect on post‑appearance detention.
2 September 2025
August 2025
A late leave‑to‑appeal application without an extension does not suspend execution; appeal upheld and urgent application dismissed.
• Civil procedure – suspension of execution – s 18(1) of the Act and Rule 49(1)(b) – timely application for leave to appeal (within 15 days) as precondition for suspension. • Belated application for leave – lapse where no court order extended the 15‑day period – s 18(1) protection inapplicable. • Mootness – court may decide merits in interests of justice. • Rule 42(1)(b) – variation/correction of own order to remove contradiction between judgment and operative order. • Costs – successful appellant awarded costs including two counsel; costs ordered on scale B (Rule 67A).
29 August 2025
A belated application for leave to appeal does not suspend execution of a judgment absent court-authorized extension under Uniform Rule 49(1)(b).
Civil procedure – Suspension of court orders pending appeal – Section 18(1) of Superior Courts Act – Rule 49(1)(b) of Uniform Rules – Failure to bring application for leave to appeal within prescribed period – Effect on right to seek suspension of order – Condonation applications do not revive lapsed right or suspend execution automatically – Public interest in finality of litigation and proper interpretation of rules.
28 August 2025
Application to strike out respondent’s claim for failure to provide particulars dismissed; punitive costs awarded for abusive litigation conduct.
Civil procedure – Interlocutory application – Request for further particulars – Delivery requirements of Rule 21(2) Uniform Rules of Court – Striking out defence – Necessity of particulars – Costs on punitive scale for dilatory and abusive litigation conduct.
26 August 2025
The court held the Minister of Police liable for the plaintiff's injuries after being negligently shot by police during a pursuit.
Delict – Police liability – Unlawful and negligent discharge of firearm by police during pursuit of a suspect – Passenger in taxi struck and injured – Evidence – Failure of defendant to call material witness – Negligence on part of police established on a balance of probabilities – Liability for damages confirmed.
26 August 2025
A magistrate’s refusal of bail was set aside on appeal where the applicant’s serious health condition constituted an exceptional circumstance.
Criminal procedure – bail appeal – schedule 6 offences – exceptional circumstances – interests of justice – health condition as exceptional circumstance – presumption of innocence – fairness of proceedings – consideration of evidence improperly omitted by lower court.
26 August 2025
Police were found liable for unlawful arrest, search, and detention, with damages awarded for the violation of constitutional rights.
Delict – Police liability – Unlawful arrest, search and detention – Requirement of reasonable suspicion – Quantum of damages – Assessment of constitutional rights violations – Absence of consent for search.
21 August 2025
Failure to admonish a competent child witness does not render evidence inadmissible; minimum sentence may be reduced if disproportionate.
Criminal law – Rape – Sentencing of minimum sentences under Criminal Law Amendment Act – Substantial and compelling circumstances – Admissibility of evidence of child witnesses – Competence and oath/admonition procedures under CPA – No automatic requirement for admonition or inquiry based solely on age – Sentence must be proportionate to the circumstances of the case.
19 August 2025
Life imprisonment for contract murder upheld; personal circumstances and advanced age not substantial and compelling justifications for deviation.
Criminal law – Sentencing – Minimum sentences – Murder – Contract killing – Substantial and compelling circumstances – Advanced age – Remorse – Appeal against sentence – Section 51(1) of Criminal Law Amendment Act 105 of 1997 – When deviation from minimum sentence justified.
19 August 2025
Application for leave to appeal dismissal of rescission of taxed costs refused for lack of reasonable prospects of success.
Leave to appeal – Taxation of costs – Service of notice of set down – Application of Uniform Rule 70 – Reasonable prospects of success – Standards for granting leave to appeal under s 17(1)(a) of the Superior Courts Act.
19 August 2025
Conviction and sentence for rape set aside where single child witness's evidence lacked corroboration and proof beyond reasonable doubt.
Criminal law – Rape – Single witness and child witness testimony – Cautionary rule – Requirement of proof beyond reasonable doubt – Forensic evidence – Evidential misdirection – Setting aside conviction where evidence does not support guilt beyond reasonable doubt.
19 August 2025