High Court of South Africa Eastern Cape, Mthatha

390 judgments
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390 judgments
Citation
Judgment date
October 2024
Condonation granted but leave to appeal dismissed: magistrate’s remand broke causation, NDPP not liable for post-appearance detention.
Condonation for late filing – reasonable explanation and substantial justice; Leave to appeal under s17 Superior Courts Act – requires reasonable prospects of success or compelling reason; Legal causation – novus actus interveniens where magistrate’s remand breaks causal link; Liability for post-appearance detention – magistrate’s remand justified by prima facie case, need for interpreter and further investigation (s204); NDPP not jointly liable for remand ordered after court appearance.
1 October 2024
September 2024
Irregular failure to have accused confirm her written plea did not vitiate conviction, but the suspended-sentence condition was vague and corrected.
Criminal procedure – guilty plea procedure under s112(1)(b) and s112(2) – duty to ascertain accused’s admissions; Plea confirmation – counsel reading plea statement – irregularity vs. prejudice; Sentencing – suspended sentence conditions must be clear, precise and related to offence; Review – s304(4)/s303 review powers and consequences of delayed transmission of record.
25 September 2024
Screening prosecutor enrolled perjury charge without reasonable cause, acted with animus injuriandi; prosecution failed, R200,000 awarded.
Malicious prosecution — elements: setting the law in motion; reasonable and probable cause; animus injuriandi; failure of prosecution — screening prosecutor’s duty to satisfy herself of prima facie evidence (A1 and warning statements); striking off roll and prolonged non‑reinstatement as failure; assessment of quantum.
17 September 2024
Respondent must file answering affidavit or Rule 6(5)(d)(iii) notice; urgent return of equipment ordered; sheriff’s costs awarded.
Civil procedure – Rule 6(5)(d) – obligation to deliver answering affidavit or, if raising only a point of law, notice under Rule 6(5)(d)(iii); counsel may not rely solely on oral submissions; urgency – removal of core switch and server causing operational prejudice; costs – sheriff protected where no basis pleaded for punitive costs against officer of court.
17 September 2024
The defendant is held liable for damages to plaintiff from a negligently caused motor vehicle collision.
Road Accident Fund liability - negligence in motor vehicle collisions - unchallenged testimony supporting plaintiff's compensation claim.
17 September 2024
A 'not guilty' verdict is irregular after a plea when a s77 enquiry finds incapacity; court must order detention/admission not acquittal.
Criminal procedure – section 77 inquiry – accused found incapable of understanding proceedings – effect of plea made before inquiry – section 77(6) and section 106(4) restrict verdicts to detention/admission or release, not acquittal – admission/detention under Mental Health Care Act – review of magistrate’s verdict.
12 September 2024
Court imposes concurrent sentences for domestic violence and murder, prioritizing retribution for heinous gender-based violence.
Criminal Law - Domestic violence and murder - Sentencing considerations - Substantial and compelling circumstances - Remorse articulation.
12 September 2024
Plaintiffs failed to prove service of the ILPACOSA statutory notice within six months; special plea upheld with costs.
Statutory notice under ILPACOSA – compliance with sections 3 and 4 – proof of service on an organ of state – onus and assessment on balance of probabilities – lost/missing documentation and contradictory affidavits – adverse inference for failure to call available witness – special plea upheld.
10 September 2024
The court upheld the municipality's right to disconnect utilities over unpaid debts not attributed to the new owner.
Municipal law – Utility services – Disconnection of services – Lawfulness of holding current property owner accountable for past owner's debts.
10 September 2024
Warrantless arrest lawful where reasonable suspicion existed from co‑accused's admission and corroborating investigative steps.
Criminal procedure — Warrantless arrest — s 40(1)(b) CPA — Reasonable suspicion may be based on co‑accused admissions and hearsay; Rule 37 pre‑trial minute and agreed documentary admissions are binding; withdrawal/striking off or co‑accused’s death does not automatically entitle civil damages for unlawful arrest.
10 September 2024
Reported
Review of MEC’s refusal to recognise a principal traditional community dismissed for failure to meet statutory requirements.
Administrative law – judicial review under PAJA and legality – delegation of provincial executive powers – interpretation of section 2B Traditional Leadership and Governance Framework Act – requirement of recognition in applicable provincial legislation – absence of rule 53 record not per se fatal – misjoinder and condonation.
5 September 2024
Urgent interim interdict to compel university registration pending review dismissed for lack of urgency and unfavorable balance of convenience.
Administrative law; interim interdict — urgency under rule 6(12); requirements for interim interdict (prima facie right, irreparable harm, balance of convenience, no alternative remedy); separation of powers — restraint of statutory/administrative action pending review; OUTA principle; academic exclusion and review remedy.
3 September 2024
Whether lodging an appeal automatically uplifts a PSIRA suspension — court held it does not; uplift is discretionary.
* Private Security Industry Regulation Act (No.56/2001) – ss 26(1),(3),(8) and s30(1) – suspension of registration; whether noting an appeal automatically uplifts suspension; Authority’s discretion to uplift. * Interim interdict – requirements (prima facie right, irreparable harm, balance of convenience) and availability of alternative administrative remedies. * Jurisdiction – territorial connecting factors and implementation of relief within court’s area. * Urgency – rule 6(12) abridgement of time. * General Law Amendment Act s35 – interim interdicts against the State (not applicable absent showing respondent is State).
3 September 2024
August 2024
Convictions set aside where the State failed to prove misappropriation or misrepresentation beyond reasonable doubt.
Criminal law — Theft and fraud — Sufficiency of evidence — Whether payments constituted misappropriation or were authorized commercial arrangements; failure to testify; civil accounting disputes not amounting to criminal misrepresentation.
30 August 2024
Committal application required fresh proof of contumacy; appellant failed to prove wilful, mala fide non-compliance.
Contempt of court — committal proceedings — where imprisonment sought, higher standard of proof applies; prior finding of contempt does not preclude fresh inquiry when circumstances change; effect of divorce on interim orders; necessity to prove wilful and mala fide non-compliance for committal.
28 August 2024
Court dismisses asylum relief: magistrate remand orders binding; statutory asylum prerequisites and exclusions unmet.
• Immigration & Refugee law – interplay between Immigration Act and Refugees Amendment Act – jurisdictional facts for detention under ss 41 and 49; • Refugee applications – requirement to report to Refugee Reception Office within five days and declaration at port of entry; • Exclusion/disqualification – prior deportation not rehabilitated and failure to report as grounds for exclusion; • Administrative law – s22(4) does not create an independent right to a permit; necessity to join statutorily empowered decision-maker; • Civil procedure – binding effect of unchallenged magistrate remand orders; forum-shopping prohibited.
27 August 2024
Plaintiff failed to prove unlawful arrest by SAPS members; trial particulars and a bail receipt were insufficient, absolution granted.
* Delict – wrongful arrest and detention – onus to prove arrest by police members and unlawfulness; police docket and SAPS registers as primary records * Civil procedure – discovery – non-production of police docket and effect on proof * Pleadings – trial particulars cannot create a new cause of action or cure material variance in pleadings * Evidence – inconsistent testimony and lone bail receipt insufficient to discharge balance of probabilities * Remedy – absolution from the instance; costs to successful defendant
27 August 2024
Plaintiff failed to prove arrest and detention by police; bail receipt alone insufficient to establish wrongful arrest.
Civil damages for unlawful arrest and detention – burden of proof on plaintiff to establish arrest by police members – police docket and SAPS registers as primary records – trial particulars cannot alter pleaded cause of action – inconsistencies and lack of corroboration undermine plaintiff’s case – absolution from instance.
27 August 2024
Failure to join the detention facility head and Minister required postponement of the applicant’s release application.
Administrative law; detention and joinder — necessity to join the detention facility’s executive authority and Minister under State Liability Amendment Act s2(1) when relief affects custody; court may raise non-joinder mero motu; inability to grant release without necessary parties.
27 August 2024
Caretaker agreement terminated for breach through unauthorized subletting; respondents ordered to vacate property.
Contracts – Caretaker Agreement – Breach and termination – Unlawful occupation and eviction – Subletting without authority – Costs.
20 August 2024
An interlocutory order remains operative despite a pending application for leave to appeal under s18(2) of the Superior Courts Act.
Administrative law – interlocutory orders – Superior Courts Act s18(1)–(3) – s18(2) preserves operation of interlocutory orders pending leave to appeal; obligation to obey court orders; costs where proceedings unnecessary.
20 August 2024
High Court enforces revived employment contract: orders immediate payment of salary, removal of office key block, and punitive costs.
Employment law; enforcement of employment contract in High Court; concurrent jurisdiction with Labour Court; effect of bargaining council award reviving employment; urgent specific performance and interdicts; costs on attorney-and-client scale.
20 August 2024
An urgent interim interdict stayed disciplinary proceedings pending review where statutory disciplinary procedures appeared not to have been followed.
* Local government disciplinary law – Local Government: Disciplinary Regulations for Senior Managers, 2010 – Regulation 5 procedural preconditions before instituting disciplinary proceedings against senior managers; * Administrative law – legality and municipal powers – municipalities must act within statutory constraints; * Interim relief – urgency, prima facie right and exceptional circumstances to interdict disciplinary proceedings in medias res; * Jurisdiction – concurrent jurisdiction issues with the Labour Court left for substantive determination.
20 August 2024
Dolus eventualis murder of a child; court found substantial and compelling circumstances and imposed wholly suspended concurrent sentences.
Criminal law – Murder and attempted murder – mens rea: dolus eventualis; Mandatory minimum sentence s51(1) Criminal Law Amendment Act – victims were children; Substantial and compelling circumstances s51(3) – factors justifying deviation (age, first offender, remorse, cooperation, family dependence, reconciliation); Sentencing – wholly suspended concurrent sentences; Firearms Control Act – declaration of unfitness to possess firearm.
19 August 2024
Plaintiff failed to prove loss of earning capacity; awarded R2,061,075 for general and future medical damages, with specified costs and interest.
Medical negligence — cannula insertion causing brachial artery obstruction and amputation; damages quantification — loss of earning capacity (proof required), general damages, future medical/prosthetic and care costs; evidentiary weight of untested expert reports; contingency deduction and effect of interim payment; costs allocation for trial days and unpaid expert testimony.
15 August 2024
Court refuses to assume supervisory jurisdiction over provincial education infrastructure despite identified overcrowding and an offered implementation plan.
Education law — Right to basic education — Classroom overcrowding — Structural interdicts and supervisory jurisdiction — Institutional competence and separation of powers — Need for needs-assessments and concrete implementation plans before judicial supervision.
13 August 2024
Court awarded 25% pre‑morbid and 40% post‑morbid contingencies for minor’s future loss of earnings; RAF to pay R915,925 plus undertakings.
Road Accident Fund — assessment of future loss of earnings for a minor — contingency deductions — appropriate higher post‑morbid contingency where permanent functional impairment causes labour‑market vulnerability; expert admissions and actuarial assumptions; section 17(4)(a) undertaking and curator bonis.
13 August 2024
Trial court’s inadequate sentencing explanation permitted review, but 18 months’ imprisonment for violent assault was upheld.
Sentencing—Zinn triad—material misdirection by silence on sentencing factors—appellate reconsideration; section 28(2) (primary caregiver v breadwinner); provocation as mitigation; relevance of prior violent convictions; custodial sentence appropriate for serious, violent assault.
12 August 2024
Whether the appellant’s cumulative six-year sentence for multiple frauds was disproportionate, requiring concurrency to 18 months.
Sentencing appeal – cumulative effect of multiple sentences – duty to consider cumulative impact even when offences at different times/places – proportionality and S v Dodo – concurrency versus consecutiveness – relevance of dated prior convictions – s282 antedating.
12 August 2024
Authority to institute proceedings must be disputed under rule 7(1); an unauthorised loan was void, but broad bond and surety may secure an enrichment claim.
• Civil procedure – authority to institute motion proceedings – role of rule 7(1) – deponent to founding affidavit not required to prove authorisation absent rule 7 challenge. • Administrative/contract law – delegation of powers – agreement void where signed without required authorised signatories and not ratified. • Property/security law – mortgage bond accessory but may secure enrichment claim if broadly drafted. • Suretyship – accessory security may be enforceable to the extent it secures enrichment claim. • Restitution – unjust enrichment (condictio) may be available where underlying contract void.
6 August 2024
July 2024
Arrest lawful, but continued detention from 21 Nov to 22 Dec 2022 was unlawful; state liable for damages.
Immigration law – Arrest and detention of illegal foreigners – Application of sections 41, 34 and 49 of the Immigration Act – Effect of Constitutional Court decisions declaring parts of s34(1) invalid and prescribing interests-of-justice and judicial oversight – Lawfulness of detention pending deportation; onus to justify continued detention; failure to call key witnesses and contradictory official evidence leads to rejection of state case.
30 July 2024
Leave to appeal refused: court may decide a fully canvassed misjoinder issue despite no prior separation order.
* Civil procedure – misjoinder and non‑joinder – whether defendant properly joined for delict arising from prosecutor’s conduct – pleadings and evidence; * Uniform Rules r 33(4) – court’s discretion to separate issues, but procedural formalism should not defeat substantive justice absent prejudice; * Superior Courts Act s 17(1) – test for leave to appeal (reasonable prospects of success/compelling reasons).
23 July 2024
Court finds accused guilty of robbery, murder, weapon possession, relying on confession, and DNA links.
Criminal Law – Robbery, murder, possession of dangerous weapon – Admissibility of confession and pointing out – Circumstantial and DNA evidence sufficiency.
17 July 2024
Application for leave to appeal against earlier spoliation judgment denied due to lack of reasonable prospect of success.
Civil Procedure – Leave to appeal – Mandament van spolie – Unlawful deprivation of property possession – Lien as defence in spoliation claim.
9 July 2024
Reported
Final protection order set aside for procedural irregularity and denial of opportunity to be heard; matter remitted for expedited rehearing.
Domestic Violence Act – interim protection order and return date – obligation to allow respondent to show cause on return date; Criminal Procedure Act s60(11),(12) – bail conditions and issuance of protection orders; review – procedural irregularity, audi alteram partem violation; conflation of bail and protection proceedings; absence of malice or bias; costs against judicial officers and State.
9 July 2024
Principal agent’s certified final account binds employer; contractor entitled to final payment certificate, payment and interest.
* Contract — JBCC 2000 — authority and binding effect of principal agent’s certification of final account and issuance of final payment certificate. * Civil procedure — motion proceedings — affidavits and documentary corroboration required; uncorroborated allegations not probable. * Arbitration/adjudication clauses — where principal agent has certified amount, no referral to adjudication arises for that certified sum. * Remedies — specific performance ordering issuance of certificate and payment, plus interest and costs.
2 July 2024
Trial court’s interventionist conduct and evidentiary gaps rendered rape and assault convictions unsafe; appeal upheld, convictions set aside.
Criminal procedure – Fair trial and impartiality – prohibition on judicial descent into the arena; cross‑examination and closing argument rights protected – Single witness evidence – cautionary evaluation where J88 inconclusive and no DNA evidence – Miscarriage of justice where trial court materially misdirects itself.
2 July 2024
June 2024
Bail appeal dismissed due to lack of exceptional circumstances despite personal and legal arguments by the appellant.
Criminal Procedure Act - Schedule 6 offense - bail refusal - exceptional circumstances - interest of justice - appeal dismissed.
28 June 2024
Applicant’s spoliation claim failed: impoundment was not shown unlawful and alternative remedies existed.
• Spoliation (mandament van spolie) — requirement to prove unlawful dispossession and absence of adequate alternative remedy. • Impoundment law — interaction of s 42(2) NRTA, s 87(1) NLTA and regulations 18 and 36(1) regarding licence/roadworthy discs and grounds for impoundment. • Urgency — commercial urgency assessed against available remedies. • Evidence standard — application of Plascon-Evans where respondent’s version not inherently far-fetched.
25 June 2024
Minority postponed prescription; defendant’s unpleaded prescription defence failed and was dismissed with costs.
Prescription — special plea — onus rests on party pleading prescription — minority delays commencement and completion of prescription — prescription may not be raised mero motu under s 17(1) Prescription Act — pleadings must state material facts; unpleaded factual bases cannot be relied on at trial.
25 June 2024
Appellate court affirms intrapartum negligence and causation findings, amending order to limit liability to representative capacity.
Medical negligence — intrapartum hypoxic-ischaemic injury and causation; medical records — vicarious admissions and evidential weight where authors not called; expert opinion — court’s duty to evaluate and may reject joint opinions; appellate review — deference to trial court credibility findings absent clear misdirection; prescription — amendment of order to limit declaration to representative claim.
25 June 2024
Occupier held fully liable after court preferred plaintiff’s account that she slipped on a wet entrance mat.
Delict — premises liability — slip and fall on entrance mat — assessment of mutually destructive versions: credibility, reliability and balance of probabilities — occupier held liable where mat rendered slippery by tracked rainwater; damages and costs awarded to plaintiff.
20 June 2024
Applicant’s loss‑of‑support claim dismissed for failure to prove a legally enforceable duty of support beyond majority.
Dependants’ action; duty of support between siblings; boni mores assessment; continuation of support beyond majority; evidentiary burden to prove binding duty; customary law considerations.
20 June 2024
Applicant’s claim to occupied rural allotment dismissed for prolonged unexplained delay, lack of possession, and superior rival evidence.
* Land law – informal land rights – IPILRA s 2(1) – protection requires proof of an existing informal right to use, occupation or access; customary practices may determine loss of an allotment. * Administrative law – undue delay and condonation – review/rights-based claims must be instituted without unreasonable delay; unexplained long delay may justify refusal to entertain relief. * Civil procedure – factual disputes in motion proceedings – where material facts are disputed and no oral evidence is sought, Plascon-Evans principle applies and declaratory relief may be refused. * Evidence – documentary proof and actual occupation (development) are material to establish entitlement and to assess prejudice to third parties.
18 June 2024
The applicant failed to prove municipal negligence or causation for injuries from an uncovered manhole.
Delict — negligence — municipal liability for manholes/stormwater drains — ownership and duty to maintain — factual and legal causation — absolution from the instance — failure to establish prima facie case.
18 June 2024
Court allowed withdrawal of blanket admissions where mistake and bona fide defence shown; prejudice curable by costs, amendment granted.
Civil procedure — Amendment of pleadings — Withdrawal of admissions — Court requires reasonable explanation for circumstances of original admission and reasons for withdrawal — Prejudice to other party must be considered; curable prejudice may be met by costs or postponement. Criminal procedure — Bail/remand — Decision to postpone bail and further detention is a judicial function of the magistrate, not a unilateral power of the prosecutor.
18 June 2024
Leave to appeal costs refused; applicants failed Rule 35(14) requirements and showed no exceptional circumstances.
Rule 35(14) URC – production of documents; necessity and relevance for pleading – reconciliation accounts and dishonoured payments; Costs – discretion of trial court; appeals on costs alone – s17 Superior Courts Act; exceptional circumstances and reasonable prospects of success; formal sufficiency of notice of appeal.
13 June 2024
The respondent liable for a rubber-bullet injury; excessive quantum claims unproven, R50,000 awarded for pain and suffering.
Police liability – rubber-bullet injury – identification of officers in daylight; admissibility and credibility of J88/medical records despite administrative date discrepancies; failure to prove past/future loss of earnings and excessive quantum; costs reduced to Magistrates’ Court scale.
11 June 2024
Appellants’ medical evidence did not establish exceptional circumstances; magistrate’s refusal of bail was not wrongly exercised.
Criminal procedure – Bail on new facts – Section 60(11)(a) (Schedule 6 offences) – Exceptional circumstances required – Appellate review limited to material misdirection of magistrate’s discretionary exercise.
11 June 2024
Appeal dismissed: improperly admitted confession excluded but voluntary community admissions and circumstantial evidence sustain convictions.
Criminal procedure – plea explanation – scope of section 115 CPA; admissibility of confessions – voluntariness and section 35(5) Constitution; extra-judicial admissions – section 219A CPA; circumstantial evidence and inferences (R v Blom).
10 June 2024