High Court of South Africa Eastern Cape, Mthatha

390 judgments
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390 judgments
Citation
Judgment date
June 2024
Trial was unfair due to failure to protect the accused’s section 35(3) rights; conviction and sentence set aside.
Criminal procedure – fair trial rights (s 35(3)) – right to legal representation and legal aid – judicial impartiality and prohibition of private communication with one party’s counsel – admission/reliance on protection orders – sentence disproportionate.
4 June 2024
Disputed allegations of a prior customary marriage required referral to oral evidence under Rule 6(5)(g).
Customary marriage — proof and corroboration — uncorroborated allegations of prior customary marriage where key witnesses are deceased; Civil marriage — potential nullity if prior customary marriage exists; Civil procedure — Uniform Rule 6(5)(g) — referral to oral evidence where disputes of fact cannot be resolved on affidavit; Procedural directions for oral evidence, subpoenas and discovery.
4 June 2024
May 2024
Court authorised execution against the judgment debtor’s primary residence under Rule 46A, set R650,000 reserve price, and awarded costs.
* Civil procedure – Rule 46A – execution against primary residence – court must consider all relevant factors before authorising sale in execution. * Requirement to excuss movables before execution against immovable property; effect of prior dismissal based on non-excussion. * Non-joinder of preferent creditors/local authority – limits and consequences. * Rule 41A mediation – discretion to refer and when refusal is justified. * Setting reserve price under Rule 46A(8)(e). * Conduct of judgment debtor (including prior contempt) as factor in Rule 46A assessment.
31 May 2024
A consent order staying a disciplinary hearing rendered the urgent challenge moot, and the employer was ordered to pay costs.
* Administrative/disciplinary procedure – interlocutory relief – urgency – stay and interdict of internal disciplinary hearing; consent order rendering relief moot. * Mootness and justiciability – courts should not give advisory opinions on abstract or academic disputes. * Costs – where consent order grants operative relief sought, successful party entitled to costs; costs follow the event.
31 May 2024
An urgent court may not suspend a lawful statutory precautionary suspension when an adequate statutory appeal remedy exists.
Administrative law — statutory suspension of registration under section 26(1) of the Private Security Industry Regulation Act — precautionary suspension versus punitive action — adequacy of statutory appeal under section 30(1) — failure to exhaust alternative remedy — urgency and punitive costs.
30 May 2024
Forfeiture under s9(1) requires proof of substantial misconduct and undue benefit; absent such proof, estate must be divided.
Divorce Act s9(1) – forfeiture of benefits – requirement to prove nature and extent of benefit; substantial misconduct necessary for forfeiture; onus on applicant to show undue benefit; appeal setting aside magistrate's forfeiture order and substituting division of joint estate.
30 May 2024
Part-payment of attorney's bill does not bar a client's demand for taxation; action must be stayed pending taxation.
Costs — Attorney-and-client bill — Disputed quantum — Section 80(4) Magistrates’ Courts Act and Rule 33(18) — Demand for taxation requires stay of action — Part-payment does not necessarily constitute acquiescence or waiver — Role of taxing master in assessing reasonableness and quantum of legal fees.
30 May 2024
Admission alone does not create a binding right to register; applicant failed to prove contract or breach of s29(1)(b).
Administrative law; contract formation — university admission versus registration; first-come-first-served online registration and availability of space; proof of offer and acceptance; right to further education (s29(1)(b)) — progressive realization and resource constraints; urgency under Uniform Rule 6(12).
28 May 2024
Eviction application dismissed because the applicant failed to prove authority to institute and prosecute the proceedings.
Procedure — Motion proceedings by artificial persons — Authority to institute and prosecute — Rule 7(1) — Proof of authorisation when challenged — Eviction application dismissed for lack of authority.
28 May 2024
Leave to appeal refused where plaintiffs failed to prove defendant dug the hole or that its negligence caused the child's drowning.
• Civil liability – wrongful death/drowning – proof of causation and identity of tortfeasor required • Evidence – inferences from conciliatory conduct (apology/contribution to funeral) do not substitute for proof of causation • Pleadings – particulars of claim must be sufficiently clear; vacillation between causes of action problematic • Procedure – leave to appeal under s17(1) Superior Courts Act requires reasonable prospects of success or compelling reasons
27 May 2024
Applicant's PAIA claim dismissed: wrong respondent cited and PAIA excluded where criminal/disciplinary proceedings had already commenced.
* Administrative law – PAIA – applicability of PAIA where criminal/disciplinary proceedings pending – s 7(1) PAIA excludes post-commencement requests for records relevant to such proceedings. * Civil procedure – citation and joinder – misjoinder/non-joinder of juristic public college v. departmental information officer. * Education law – Further Education and Training Act s 45 – access to college records in exercise and protection of rights during disciplinary processes. * Costs – Biowatch principles applied; no order as to costs in public-rights litigation.
24 May 2024
An owner's tender of adequate security in attorneys' trust defeats a lien, warranting court-ordered release of a towed vehicle.
Possessory lien – Towing and storage charges – Adequacy of substitute security (attorney's trust account) to defeat lien – Disputes about contract and reasonableness are for trial – Court may order release of towed vehicle and authorize sheriff.
23 May 2024
Leave to appeal dismissed: declaratory relief resembling review is subject to undue-delay/condonation rules and proceedings were res judicata.
Administrative law – declaratory relief framed as review – undue delay and condonation; Civil procedure – Rule 49(4) notice of appeal requirements; Res judicata and 'once and for all' rule – substance over form; Dispute of fact on papers – need for referral to oral evidence; Costs – costs follow event, appellate restraint absent exceptional circumstances.
21 May 2024
Assessor irregularities and unsworn witness testimony vitiated the applicant's conviction and sentence.
* Criminal procedure – Assessors – Section 93ter(3) requires assessors to be sworn before hearing evidence; failure is a peremptory irregularity rendering assessments invalid. * Criminal procedure – Assessors – Trial proceeding with one assessor after recusal requires judicial exercise of discretion with reasons on record; lack thereof vitiates proceedings. * Criminal procedure – Prosecutor’s private communications with assessors outside court prejudicial and irregular. * Evidence – Witness testimony must be under oath or affirmation (s162 CPA); unsworn testimony inadmissible. * Criminal procedure – Section 170 CPA applies to accused persons; convicting a witness under s170 is unlawful.
17 May 2024
Court admitted confessions, accepted accomplice corroboration and convicted accused on multiple counts, finding common purpose liability for accused 5.
Criminal law – admissibility of confessions and pointings out to commissioned officers – voluntariness; Accomplice evidence – caution and corroboration; Common purpose – liability of participant who withdraws late or not at all; Late‑raised alibi – probative value; Ballistics/forensic corroboration of confessions.
17 May 2024
Assault proved; defendant liable for all injuries as initial assault causally linked to subsequent harm.
Delict – assault – proof of assault and causation; medical J88 evidence; application of factual (but‑for) and legal causation; weight of inconsistent defendant evidence and effect of criminal plea on civil liability.
16 May 2024
Applicant failed to justify rescission of order striking out its defence and raised new grounds impermissibly in reply.
Pleadings and affidavits — clarity and brevity required; rescission of order striking out defence — applicant must explain non-compliance and show prospects of success; new grounds in replying affidavit — impermissible and prejudicial; Rule 60 procedure for striking out — drastic remedy requiring full factual basis; Rule 49(8) reliance cannot be raised for first time in reply.
15 May 2024
Leave to appeal refused for lack of reasonable prospects; punitive attorney-and-client costs awarded.
Civil procedure – Urgent applications and reconsideration under Uniform Rule 6(12)(c) – Rule 6(5)(c) not applicable to anticipation of urgent reconsideration – Leave to appeal under section 17 Superior Courts Act requires reasonable prospects of success – Mootness of relief confined to interdict of burial – Frivolous litigation may attract attorney-and-client costs.
14 May 2024
Failure to testify undermined quantum proof; expert opinions need factual foundation; absolution from the instance ordered.
Employment law – wrongful dismissal – quantum of damages – plaintiff’s duty to give evidence where central facts are exclusively within her knowledge; expert opinion requires factual foundation; absolution from the instance appropriate where plaintiff’s evidence has potential to succeed.
14 May 2024
Leave to appeal refused where relief was overbroad, claimants were not joined, and writs stemmed from unchallenged court orders.
Urgent applications — stay of execution — overly broad/unclear relief and failure to join necessary parties; leave to appeal — reasonable prospects of success required under s17(1) Superior Courts Act; execution of writs obtained pursuant to unchallenged court orders; Board Notice 271 of 2022 — prior litigation and invalidation of certain clauses.
10 May 2024
Conviction set aside where guilty plea was accepted without proper s112 questioning and magistrate’s demeaning conduct.
Criminal procedure – guilty plea – section 112(1)(b) CPA – judicial questioning to establish admission of elements; Criminal procedure – section 113 CPA – change of plea to not guilty where defence appears; Right to legal representation – accused must be informed and able to exercise right; Sentencing – sentence must be founded on competent facts and law, cannot punish for uncharged conduct; Judicial conduct – demeaning language by presiding officer may constitute misconduct; Review – conviction and sentence set aside and immediate release ordered.
9 May 2024
Applicant failed to prove exceptional circumstances for bail in a Schedule 6 robbery; appeal dismissed.
Criminal procedure – Bail – Schedule 6 offence – section 60(11)(a) – onus on accused to prove exceptional circumstances – identification evidence and recovered property can sustain a prima facie case – appellate review under section 65(4) limited to misdirection or wrongful exercise of discretion; immigration status, health and family dependence do not automatically constitute exceptional circumstances.
2 May 2024
Applicants failed to show exceptional circumstances or evidence to interdict disciplinary hearings pending review.
Urgent interim relief — disciplinary inquiries — intervention in ongoing internal disciplinary processes requires exceptional circumstances; motion proceedings require adequate factual pleading and supporting documents; distinction between trusts, NPOs and NPCs relevant to locus and employer authority; EMIS registration number not equivalent to company registration; alternative remedies (disciplinary point in limine, CCMA, review) available.
2 May 2024
Completed investigation, deteriorating health and financial prejudice can constitute exceptional circumstances justifying bail.
Bail — renewed application on new facts — completion of investigation; exceptional circumstances under s60(11)(a) — deteriorating health, financial prejudice and pending forfeiture; pre‑trial delay; State’s duty to rebut uncontested allegations; conditions to protect witnesses and ensure attendance.
2 May 2024
Completion of investigations, health deterioration, trial delay and forfeiture prejudice amounted to exceptional circumstances justifying bail.
Bail — renewed application on new facts — completion of investigations, trial delay, deteriorating health and pending forfeiture can constitute new facts and exceptional circumstances under s 60(11)(a) CPA; appeal under s 65(4) — appellate court may set aside refusal if lower court was wrong; risk to witnesses/public must be assessed with reference to s 60(7) and rebutted by evidence.
2 May 2024
April 2024
Court upheld MEC’s PAJA-regulated investigation and recognition of a traditional headman as lawful and procedurally fair.
Administrative law – PAJA review of administrative action – Recognition of traditional leader – Delegation of Premier’s powers to MEC – Uniform Rule 53 record – Customary succession and role of royal family – Procedural fairness (audi alteram partem) – Plascon‑Evans application vs referral for oral evidence (Rule 6(5)(g)).
30 April 2024
Condonation granted but leave to appeal refused due to delay, unpleaded DZ defences, and reasonable damages assessment.
Appeal — condonation granted for late filing; leave to appeal refused — no reasonable prospect of success or compelling reason (s 17(1)(a) SCA). Amendment of pleadings — DZ defences — inordinate delay, failure to plead or prove defences, and prejudice to respondent. Quantum — substantial agreement on most heads; court‑assessed caregiving and housing reasonable on evidence. Costs awarded, including two counsel.
25 April 2024
Applicant interdicted unlawful development in protected coastal conservation area; respondent’s claimed permission to occupy was unproven.
Environmental law – Coastal conservation area (Decree 9 of 1992) – Development permitted only by departmental permit; Proclamation 26 of 1936 – permissions to occupy and transfers – Motion proceedings: burden and quality of evidence; hearsay inadmissible where primary witnesses available – Final interdict requisites – alternative remedies – Rule 16A and pleading of constitutional issues.
23 April 2024
March 2024
Tender withdrawal based on erroneous legal assumptions set aside; applicant substituted as successful bidder.
Municipal procurement – tender requirements and CIDB grading – compliance with mandatory conditions; notice of intention to award and effect on tender validity; withdrawal/cancellation of tender – PAJA reviewability, procedural fairness and rationality; substitution remedy and exceptional circumstances (Trencon principles); procurement must meet s217 Constitution fairness, transparency and cost-effectiveness.
28 March 2024
Late lodgement of leave to appeal did not extinguish appeal rights; section 18 suspended execution of the orders.
Suspension pending appeal — s18(1) Superior Courts Act — effect of belated application for leave to appeal; interplay between rule 49(1)(b)/(6) and s18; condonation and non-compliance; discretionary stay under rule 45A and interlocutory interdict principles.
27 March 2024
An employee with keys and day‑to‑day control had locus to claim spoliation; restoration of possession and interdiction were granted.
Urgent spoliation (mandament van spolie) – possession by employee sufficient for locus standi – proof of peaceful and undisturbed possession and wrongful deprivation – switching off electricity as spoliation – inadmissibility of unproduced confirmatory affidavits – non‑joinder objection dismissed.
26 March 2024
Minister properly joined as executive authority, but the NDPP/NPA must be joined due to its direct and substantial interest.
* State liability – citation of executive authority – section 2(1) State Liability Act – Minister as nominal defendant. * Constitutional and statutory framework – section 179 Constitution; National Prosecuting Authority Act – Minister’s concurrence on prosecution policy, salary scales, and departmental accounting. * Employment and vicarious liability – prosecutor employed by NPA under contract; dual principalship; employer’s direct and substantial interest. * Joinder and non-joinder – test whether a third party has a direct and substantial interest in orders the court may make.
19 March 2024
The respondent failed to prove public provision of equivalent caregiving; the applicant entitled to lump‑sum caregiving damages.
Delict — damages for future caregiving — entitlement to lump‑sum award; public‑healthcare defence — evidentiary burden to prove equivalent public provision at no/less cost; refusal to develop common law to permit deferred/state‑provided caregiving; contingency deduction rejected.
18 March 2024
Amendment refused: proposed personal‑injury damages lacked Rule 18(10) particularity and would render pleadings excipiable.
Rule 18(10) – Particularity in claims for damages for personal injury; pleadings must state earnings lost to date and how quantum is made up; non‑compliance is prima facie prejudicial and may render pleadings excipiable; post‑notice expert reports do not cure an inadequate notice to amend.
5 March 2024
February 2024
An admission offer does not create enforceable registration rights absent payment and available space; applicant failed to prove either.
Contract formation — admission offer subject to suspensive condition of registration fee and capacity; failure to prove payment or frustration — no enforceable right to registration; constitutional right to further education does not guarantee enrolment at a particular institution; motion proceedings require adequate affidavit evidence and a replying affidavit where material disputes exist.
27 February 2024
Supplementary affidavits and a hastily framed Rule 30A notice were procedurally defective and set aside; leave to refile granted.
Practice and procedure — Urgent applications and Rule 12 — readiness of papers when seeking urgency; Further affidavits — limits on filing supplementary affidavits and amendments to affidavits (Rule 28; Rule 6(5)(e)); Rule 30A — enforcement for failure to comply with rules or court directions; Rule 30(1) — setting aside irregular steps where opposing party not afforded opportunity to remove cause of complaint; Timing and procedural compliance required for notices under Rules 30 and 30A.
13 February 2024
Plaintiffs awarded substantial damages for unlawful arrest, detention and degrading assault, including forcible ingestion of dog faeces.
Unlawful arrest and detention – assessment of quantum – assault and degrading treatment – forced ingestion of dog faeces as aggravating factor – racial motive as aggravation – evidentiary consequences where defendant fails to call witnesses or opposing experts – awards for solatium and future medical expenses.
1 February 2024
January 2024
Applicant lacked standing to challenge a municipal resolution because a binding consent order governed his employment.
Standing – Superior Courts Act s21(1)(c) – requirement of direct and substantial interest for declaratory relief; Leave to appeal – s17(1)(a) – reasonable prospects of success; Motion proceedings – disputed facts resolved under Plascon‑Evans; Effect of existing consent court order on locus standi to challenge municipal resolutions; Annexures not properly pleaded cannot be relied upon.
30 January 2024
Application to admit late evidence of lobola payment fails; hearsay excluded and appeal dismissed with costs.
* Family law – validity and proprietary consequences of marriage – allegation of prior customary marriage founded on alleged payment of lobola – admissibility of hearsay evidence. * Evidence – hearsay in civil proceedings – Law of Evidence Amendment Act; requirements for admission and the need to call source/declarant. * Appeal – admission of further evidence on appeal – principles (finality, diligence, weight, prejudice). * Mootness – appeal not dismissed solely on mootness where declaratory relief remains distinct.
30 January 2024
Appellant’s extant PTO (until set aside) entitled eviction; counter-claim defective for non-service and failure to seek PAJA review.
* Land tenure – Permission to Occupy (PTO) – PTO remains extant until set aside or cancelled by issuing authority or court. * Administrative law – Challenge to PTO requires service on and review of the issuing state department under PAJA; direct and substantial interest of state. * Eviction – PIE s 4(7) and s 26(3) constitutional balancing of landowner/occupier interests; just and equitable inquiry. * Family/common home claims – interplay between customary/family rights and statutory PTO tenure; evidentiary and locus standi implications.
30 January 2024
23 January 2024
Consent order upheld where applicants failed to plead or prove grounds for rescission and produced no confirmatory affidavits.
Civil procedure – rescission of consent judgments; Rule 42(1) – statutory grounds for rescission; Common law rescission – fraud or justus error required; Necessity of confirmatory affidavits from counsel/instructing attorneys; Finality of judgments; Withdrawal of attorney – procedural obligations under Rule 16 and Joint Rules.
23 January 2024
Court grants eviction where leases expired/terminated, PIE complied with, and respondents raised no bona fide defenses.
Eviction – PIE compliance – termination of leases by effluxion of time/notice; bona fide disputes of fact; Plascon–Evans principle; lessee bound despite lessor’s lack of title; costs including two counsel.
23 January 2024
23 January 2024
Factual admissions in a section 112(2) plea can suffice to prove intention and penetration; appeal dismissed.
Criminal law – section 112(2) plea statements – factual averments must support elements of offence; intention may be inferred from facts; admission of penetration by accused; appellate interference limited absent material misdirection.
23 January 2024
December 2023
Arrest was lawful because reasonable suspicion of malicious injury (Schedule 1) existed and detention complied with statutory and constitutional limits.
* Criminal procedure – Warrantless arrest – s 40(1)(b) CPA – jurisdictional facts: peace officer, suspicion, Schedule 1 offence, reasonable grounds. * Malicious injury to property as basis for Schedule 1 arrest where assault charge (Schedule 7) is also present. * Exercise of police discretion to arrest – standard of rationality and protection of persons from mob violence. * Detention – distinction between lawfulness of arrest and of detention; compliance with 48‑hour rule and court’s discretion to order continued detention.
12 December 2023
Accused failed to prove exceptional circumstances for bail under section 60(11)(a) for a Schedule 6 offence.
Bail – Schedule 6 offences – s60(11)(a) Criminal Procedure Act – onus on accused to prove exceptional circumstances; ordinary personal circumstances (employment, parenthood) insufficient without more; strength of State case (possession of vehicle, matching fingerprints) and credibility issues relevant to bail refusal.
12 December 2023
A spoliation order can restore possession wrongfully taken by a municipality, but not return property to an unlawful site.
* Property — Mandament van spolie — Possessory remedy — Applicant must prove prior de facto possession and wrongful dispossession. * Administrative action — Municipality — Impoundment of container — absence of identified statutory authority renders dispossession wrongful. * Civil remedies — Relief limited by doctrine of legality — court will not order restoration to an unlawful site. * Evidence — Opposing affidavit by unconnected deponent may be disregarded; ownership not decisive in spoliation proceedings.
8 December 2023
Applicant's self-created urgency led to the urgent application being struck off and costs awarded against the applicant.
Urgency – self-created urgency – failure to respond to demand and omission to seek interim interdict – rescission of taxed bill of costs and allocator – writ of execution and attachment – application struck off roll; costs awarded.
6 December 2023
Applicant failed to establish entitlement to an interdict or permanent declaratory relief; leave to appeal refused with costs.
• Administrative law – traditional leadership – MEC’s statutory powers to enquire into and withdraw recognition of headmen – implications for entitlement to interdict and declaratory relief. • Civil procedure – requirements for a final interdict: clear right, injury, absence of alternative remedy – failure to establish same. • Declaratory relief – discretion to grant permanent declarations where statutory review/enquiry mechanisms exist. • Appeals – leave to appeal refused where no reasonable prospects of success or compelling reasons shown.
5 December 2023