High Court of South Africa Eastern Cape, Mthatha

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390 judgments
Citation
Judgment date
December 2023
Applicant’s delictual claim against an organ of state not prescribed; late statutory notice condoned.
Prescription — s 12(3) Prescription Act: a debt is not due until creditor knows identity of debtor and facts giving rise to debt; mere suspicion insufficient; Institution of Legal Proceedings Against Certain Organs of State Act 40 of 2002 s 3 — notice requirement and condonation (good cause, non-extinction by prescription, no unreasonable prejudice); application of Truter v Deysel, Minister of Finance v Gore, and Lakay.
5 December 2023
November 2023
Arrest and four-day detention unlawful where police failed to prove reasonable suspicion or justify arrest; R160,000 awarded.
* Criminal procedure – Arrest without warrant – s 40(1)(b) and (g) CPA – jurisdictional facts: peace officer, suspicion, offence in Schedule 1/Stock Theft Act, reasonable grounds for suspicion. * Stock theft – possession (corpus and animus) and requirement to give a satisfactory account under Stock Theft Act s 2. * Constitutional law – right not to be arbitrarily deprived of freedom (s 12(1)) – unlawful arrest and detention. * Evidence – onus shifts to state to justify arrest once arrest admitted; failure to call arresting officer may attract adverse inference. * Remedies – damages for unlawful arrest and detention; assessment of quantum for infringement of personal liberty.
28 November 2023
Application for mandament van spolie dismissed; lack of peaceful possession negates spoliation claim.
Civil Procedure – Mandament van spolie – Requirement of peaceful and undisturbed possession – Tacit hypothec.
14 November 2023
Applicant failed to establish mandament van spolie where respondent retained goods under asserted tacit hypothec after lease termination.
Mandament van spolie – requirements for restoration of possession; lease and tacit hypothec; locus standi; retention of movable property to recoup arrear rentals; opposed urgent application.
14 November 2023
A warrantless arrest under s40(1)(a) and subsequent detention were lawful; the applicant's claim dismissed.
Criminal procedure – Arrest without warrant – s40(1)(a) CPA – honest and reasonable belief of offence in presence of officer; Delict – unlawful arrest and detention – onus on state to justify interference with liberty; Section 50 CPA – bringing arrested person to court within reasonable time; Credibility and probabilities in resolving conflicting versions.
14 November 2023
Section 112(2) statements that omit essential elements and notice of common-purpose sentencing render plea proceedings unfair and convictions unreliable.
Criminal procedure – section 112(2) statements – must admit factual and mental elements of offences; Magistrate obliged to question under s112(1)(b) to ensure admissions legally sustain conviction; Charge sheet must disclose reliance on common purpose to attract s51(1) minimum sentence; Defective s112(2) statements and failure to clarify omissions = unfair plea proceedings and miscarriage of justice; Convictions and sentences set aside and matter remitted for compliant plea proceedings.
14 November 2023
Arrest unlawful where suspicion relied on unverified warning statements and interpreter verification was not obtained; post-appearance remand not the defendants’ liability.
Criminal procedure – arrest without warrant – reasonable suspicion – reliance on co-accused warning statements – duty to verify and obtain interpreter for deaf/mute suspect; detention – distinction between pre-appearance detention (lawfulness depends on arrest) and post-appearance remand (determined by court orders and causation); liability – police liable for unlawful arrest/detention pre-appearance; NDPP not jointly liable for remand resulting from court processes.
7 November 2023
Appellate court reduced excessive damages for unlawful arrest, stressing necessity of detailed evidence to quantify non‑patrimonial loss.
Unlawful arrest and detention — quantification of non‑patrimonial damages — pleadings cannot substitute for oral or expert evidence — prior awards for guidance not as fixed benchmarks — appellate reduction of excessive award.
7 November 2023
A geographic regulation criminalising unauthorised coastal development in the former Transkei is rational, not unfairly discriminatory, and remains valid.
Constitutional law – Equality (s 9) – Challenge to s 39(2)(c) of Environmental Conservation Decree – Harksen test applied – Differentiation between coastal conservation area and elsewhere found rationally connected to legitimate environmental purpose and not unfair discrimination; Decree remains applicable in former Transkei; decision to prosecute not reviewable. Costs – Biowatch principle – each party to pay own costs.
1 November 2023
Appellants failed to prove exceptional circumstances under section 60(11)(a); bail refusal upheld.
* Criminal procedure – Bail – Section 60(11)(a) – Onus on accused to prove exceptional circumstances for release on Schedule 6 offences. * Bail – Consideration of strength of State’s case, likelihood of evasion or interference with witnesses. * Confessions and pointing out – admissibility disputes do not by themselves constitute exceptional circumstances. * Personal circumstances (employment, address, surrender) are ordinarily insufficient to justify bail.
1 November 2023
October 2023
Applicants failed to prove contractual entitlement to 1.5x Sunday/public-holiday pay; genuine dispute of fact — appeal dismissed with costs.
Labour law — contractual entitlement to allowance for Sunday/public-holiday work — proof of employment contract required; motion proceedings inadmissible where genuine dispute of fact exists; Basic Conditions of Employment Act s33 (information about remuneration) — no relief where substantive entitlement not established; costs — ordinary costs despite abuse of process finding.
31 October 2023
Appellant failed to show exceptional circumstances for bail on Schedule 6 charges; magistrate’s refusal was upheld.
Criminal procedure – bail on new facts – section 60(11)(a) exceptional circumstances required for release on Schedule 6 offences – appellate review under section 65(4) – new facts must be considered cumulatively with old facts – striking of related matter from roll does not preclude future prosecution – witness safety and possibility of recall relevant to bail risk assessment – right to choose counsel not absolute.
31 October 2023
Applicant established unlawful police dispossession of 70 goats; mandament van spolie ordered and goats to be restored within 72 hours.
* Mandament van spolie – requirement of peaceful and undisturbed possession and unlawful dispossession – possession protected irrespective of title. * State Liability – executive head of department as nominal respondent; non-joinder of station commissioner unnecessary where no necessity shown. * Criminal Procedure Act (ss 20, 22) – seizure under colour of law must comply with statutory requirements; non-compliance renders seizure unlawful. * Urgency – applicant relying on livelihood may establish urgency under Rule 6(12)(b). * Burden on state to produce corroborative evidence when alleging third-party claims of ownership.
19 October 2023
Reported
Arrest and two-day detention unlawful where police suspicion lacked reasonable grounds and discretion was exercised for an improper purpose.
• Criminal procedure — lawful arrest — s 40(1)(g) CPA — reasonable suspicion of possession of stock suspected to be stolen; • Exercise of discretion by arresting officer — mala fide or improper purpose v bona fide/rational exercise; • Unlawful arrest renders ensuing detention unlawful unless justified; • Onus on state to justify arrest and detention; • Quantum for unlawful arrest and detention — compensation for deprivation of liberty and indignity.
19 October 2023
September 2023
Appellant’s condonation for pervasive procedural defaults refused; appeal dismissed for inadequate explanations and no demonstrated prospects of success.
Civil procedure — Rule 49 — condonation for procedural non-compliance — late notice of appeal, late record, late affidavits — explanation must be full, detailed and candid; attorney’s death/neglect not automatically excusing delay; prospects of success and finality relevant in exercise of discretion.
26 September 2023
An arrest executed under a warrant that fails to comply with s43(1)(a) is invalid, rendering ensuing detention unlawful.
* Criminal procedure – Warrant of arrest – statutory requirements under s43(1)(a) – warrant must set out the offence; non‑compliance renders warrant invalid. * Arrest and detention – lawfulness – arrest under invalid warrant unlawful and detention consequent thereon unjustified if State fails to discharge onus. * Proof and onus – State bears onus to justify arrest and detention; mere execution of a magistrate’s form does not cure statutory defects. * Quantum – damages for unlawful detention assessed on compensatory basis, taking into account seriousness of charge and conduct of police.
19 September 2023
The assistant Master’s appointment of a co-executor was unlawful and procedurally unfair and is set aside.
Administration of estates – section 18(1) Administration of Estates Act – limits on Master’s power to appoint executors where sole executor already appointed; review under section 95 – PAJA – procedural fairness (failure to afford right to consult legal advisor and make representations) – statutory interpretation (Endumeni, Cool Ideas) – counter-application to remove executor (section 54) dismissed.
14 September 2023
Applicant’s arrest and detention held unlawful; respondent liable and ordered to pay R650,000 damages.
Police law – unlawful arrest and detention – duty to investigate exculpatory evidence before forming reasonable suspicion – effect of struck‑out defence and non‑appearance – liability for post‑hearing detention – assessment of non‑patrimonial damages.
5 September 2023
A genuine dispute whether the land is allotment 47 or 26 made the eviction application unsuitable for resolution on affidavit.
Rural land tenure; permission to occupy; dispute as to allotment no. 47 v 26; motion proceedings—real, genuine dispute of fact; inadmissibility of unauthenticated community meeting minutes/hearsay; necessity for oral evidence or trial direction when central facts are disputed; PIE Act considerations.
5 September 2023
August 2023
Accused convicted of premeditated, common‑purpose murders; prescribed life sentences imposed and no substantial and compelling circumstances found.
Criminal law – Murder and arson – Pre‑meditation and common purpose – Application of section 51(1) Minimum Sentences Act; Section 51(3) – substantial and compelling circumstances – mitigation evidence and credibility; Sentencing triad – crime, offender and society; Firearms Control Act section 103 – unfitness to possess firearms.
30 August 2023
Failure to comply with disclosure orders does not alone justify striking out a defence; deliberate contempt must be proven.
Civil procedure – Rule 30A – remedy for non‑compliance with discovery orders; striking out of defence as a drastic remedy; contempt/contumacy requirements (order, service, non‑compliance, wilfulness and mala fides); wasted costs as alternative sanction.
23 August 2023
Failure to comply with discovery orders does not automatically justify striking out a defence; deliberate contempt must be proven.
Civil procedure – Rule 30A – failure to comply with discovery order – striking out defence as drastic remedy – high threshold requiring deliberate, contemptuous disobedience – once order, service and non-compliance shown respondent bears evidential burden on wilfulness/mala fides – appropriate alternative remedy: costs order.
23 August 2023
Employer must show agreed 6% shift-allowance rate on payslips; courts will not re-determine salaries governed by collective agreements.
Labour law; BCEA s33(1)(g) – employer’s duty to give written pay particulars; payslips must state shift-allowance rate; collective agreements and staff establishment determine salaries and limit judicial interference; doctrine of legality and administrative transparency.
22 August 2023
Warning statement and confession excluded for voluntariness concerns; insufficient evidence, accused acquitted and discharged.
Criminal procedure – admissibility of incriminating statements (warning statement s219A; confession s217 CPA) – voluntariness and constitutional safeguards; police procedure and record‑keeping; trial‑within‑a‑trial; section 174 discharge for lack of prima facie case.
21 August 2023
Whether the applicant was validly married by customary law and entitled to the homestead — court confirmed the customary marriage and relief.
Customary marriage — Recognition of Customary Marriages Act s3(1) — requirements: age, consent, negotiation/celebration (lobola, umendlaliso/utsiki) — proof on preponderance of probabilities; Credibility assessment — corroboration by elder family members; Interim relief — confirmation of rule nisi and eviction order; Spouses’ equal status under s6 and consequences for estate.
15 August 2023
Assault claim dismissed: plaintiff provoked brawl; defendant’s intervention amounted to self‑defence; each party bears own costs.
Civil liability for assault – conflicting versions – credibility and probabilities – self‑defence and necessity to restore order on commercial premises – failure to call material witnesses – costs awarded on no‑order basis.
8 August 2023
Arrest and detention lawful where officer had reasonable suspicion from child and medical evidence.
Criminal procedure — Arrest without warrant (s40(1)(b) CPA) — Reasonable suspicion formed from child’s statement and J88 medical report — Hearsay/commissioning of child statements — Use of less invasive methods versus arrest — Detention and bail discretion (s60(11)(a)).
1 August 2023
July 2023
Whether arrest under s40(1)(b) and subsequent prosecution were unlawful and whether absolution should be granted.
* Criminal procedure – arrest without warrant – s40(1)(b) – reasonable suspicion and jurisdictional facts for Schedule 1 offences; * Exercise of discretion – must be shown to be arbitrary, in bad faith or improperly exercised to succeed; * Detention – separable from lawfulness of arrest; * Malicious prosecution – elements require setting law in motion, lack of probable cause, malice, and failure of prosecution; plaintiff failed to adduce prima facie evidence; * Ministerial liability – no basis shown to hold Minister of Justice and Correctional Services liable.
18 July 2023
Applicant’s self-review of an acting municipal manager’s withdrawal of charges dismissed for lack of merit and undue delay.
Administrative law; legality review by employer of its own decision; Systems Act s55 — municipal manager powers to maintain discipline; disciplinary procedure — whether functus officio once panel constituted; collective agreement (DC Code) and silence on withdrawal of charges; forum shopping and appropriate forum (Labour Court v High Court); condonation for delay in review applications; requirements of candid pleadings and calling decision-maker.
16 July 2023
Leave granted to appeal legal questions about defective arrest warrants and lawfulness of arrest and detention under the CPA.
* Criminal Procedure Act ss 44 and 50(1)(a) — warrant of arrest — prescribed form — omission of place to which arrestees must be taken — effect on lawfulness of arrest and detention. * Legality of police conduct — obligation to take detainees to police station as soon as possible versus detention elsewhere for interrogation. * Discretion to arrest — execution of warrant versus police discretion not to effect arrest. * Constitutional protections — right not to be deprived of freedom arbitrarily; right to dignity and freedom from violence and torture. * Leave to appeal — prospects of success or compelling reasons under s 17(1) Superior Courts Act.
11 July 2023
Review of Provincial House decision dismissed for lack of pleaded facts, compliance with audi, and failure to place record before court.
Traditional leadership disputes – review of Provincial House decision – whether internal remedies must be exhausted; audi alteram partem in investigatory inquiries; role of ad hoc investigative committees (non‑binding recommendations); duty to place relevant record portions before court in motion review proceedings; requirement to plead factual basis for declaratory and reinstatement reliefs.
4 July 2023
A prior massed will is invalid where the joint estate was dissolved by divorce and the survivor failed to adiate; executor removed.
* Succession law – Massed (mutual) wills – requirements for statutory massing and adiation – massing requires consolidation of assets and valid adiation by survivor. * Divorce/deed of settlement – dissolution and division of joint estate may invalidate prior massed will if no consolidated massed estate remains. * Evidence – failure to produce original will permits presumption of revocation; defective/undated adiation documents insufficient. * Interpretation – ambiguity in mutual wills attracts presumption against massing. * Executors – appointment based on invalid will is invalid; Master to remove executrix.
4 July 2023
A customary marriage was valid despite lack of formal bride handover; symbolic delivery and lobola negotiations suffice under s 3(1)(b).
Customary marriages – Recognition of Customary Marriages Act s 3(1)(b) – validity where lobola negotiations and celebratory rites occurred; handing over not strictly required; living customary law; emissaries may represent family; mental capacity requires evidence.
4 July 2023
The High Court lacks jurisdiction over the applicant’s dismissal dispute, which falls within the Labour Court’s exclusive jurisdiction.
Employment law; jurisdiction — BCEA s77 and LRA s157; exclusive jurisdiction of Labour Court for employment disputes; repudiation of contract not established or properly pleaded; substance over form in jurisdictional analysis.
4 July 2023
Court finds urgency and Rule 34A satisfied and orders R3.2m interim payment for minor’s urgent medical needs.
* Rule 34A – interim payment for future medical costs and loss of earnings – requirements satisfied where merits established and documentary/ expert evidence of immediate needs exist. * Urgency – Rule 6(12) – best interests of the child and ongoing prejudice justify condonation of non-compliance. * Public healthcare defence/amendment to plea affects form (cash or in-kind) of ultimate award but does not preclude interim cash relief. * Interim payment should be a reasonable proportion of likely quantum, not the full claimed amount.
4 July 2023
June 2023
A young claimant’s future loss award based on a teaching career reduced by a 35% contingency; R7,967,860 awarded.
Road Accident Fund – quantum — past and future loss of income and earning capacity — selection of pre-morbid career scenario — application of Kerridge approach to contingency deductions — 35% deduction for youthful claimant with uncertain earnings proof and residual capacity — costs on attorney-and-client scale including two counsel.
27 June 2023
PAJA extension refused where challenge to Premier's recognition was unreasonably delayed and s21 internal remedies were inapplicable.
* Administrative law – PAJA s 7(1), s 9 – 180‑day time limit and condonation for judicial review of administrative action; undue delay and interests of justice. * Traditional leadership – Framework Act s 21 – scope of internal remedies; s 21 remedies inapplicable where dispute challenges Premier’s recognition/delegate decision. * Delay – when internal remedies do not exist, the 180‑day PAJA period runs from awareness of the administrative action. * Condonation – factors: extent and cause of delay, explanation covering entire period, prospects of success, prejudice and public interest in finality. * Costs – Biowatch principle: bona fide constitutional litigation against the state warrants each party bearing its own costs.
20 June 2023
The plaintiffs’ arrests and detention were unlawful; defective warrant execution and assault led to vicarious liability and damages.
Criminal procedure – Arrests and warrants (s 43–44 CPA) – Execution of warrants and officer’s discretion to arrest – s 50 CPA compliance (bringing arrested person to station/court and 48‑hour rule) – Vicarious liability of Minister for police delicts – Assault/torture in custody – Pleading adequacy for alternative grounds of unlawfulness.
20 June 2023
Omission of a stated hearing day and failure to serve set-down on a municipal manager renders default judgment ineligible and rescindable.
Civil procedure – default judgment – Uniform Rule 6(5)(b)(iii) (Form 2(a)) – omission of stated day for hearing is material, implicates audi alteram partem and may render judgment erroneously granted; Eastern Cape Rule 23(m) – applies to municipalities as organs of state; notice of set down must be served on municipal manager or State Attorney; rescission under Rule 42(1)(a).
13 June 2023
The defendant has no reasonable prospect to appeal awards for loss of income, caregiver/domestic and architectural services.
Civil procedure – application for leave to appeal – section 17(1) Superior Courts Act – elevated threshold; Evidence – evaluation of expert opinion – necessity of logical reasoning and factual basis; Damages – loss of income (educational prognosis and actuarial computation); Damages – caregiver/domestic services (agreement on need; dispute limited to cost); Damages – architectural modifications (SABS compliance; factual adequacy of dwelling).
13 June 2023
May 2023
Substandard foetal monitoring and delayed C‑section caused intrapartum hypoxic brain injury; joint expert minutes proved causation.
• Medical negligence – obstetric care – substandard fetal heart‑rate monitoring and delayed caesarean section – causation of intrapartum hypoxic ischaemic encephalopathy. • Expert evidence – joint minutes between parties’ experts binding on issues agreed and decisive for causation absent timely repudiation. • Procedural – Uniform Rule 49 non‑compliance may attract costs sanctions but court may exercise discretion to hear merits. • Sentinel event defence – sudden maternal collapse after spinal anaesthesia insufficient to displace causation established by joint expert opinion.
11 May 2023
Court dismissed application to validate ambiguous codicil under s2(3) for lack of proof of the testator’s intention.
Wills Act s2(3) — intention to be will — formalities and authentication of codicils — handwriting and signature identification — interested witness/spouse and s4A implications — onus on applicant to prove testamentary intention.
10 May 2023
Reported
An applicant should ordinarily serve a Rule 30A notice before a Rule 35(7) application; failure may affect costs.
Civil procedure — Discovery — Uniform Rule 35(7) remedy to compel discovery — Interaction with Uniform Rule 30A — Sound practice requires prior Rule 30A notice before application to compel — Non‑compliance with Rule 30A does not automatically preclude relief but affects exercise of discretion and costs.
9 May 2023
Applicants' failure to prove parental locus standi warranted dismissal of their challenge to the school's teacher advertisement.
* Administrative law – locus standi – parental standing to challenge SGB decisions – burden to aver particulars when locus standi challenged. * Schools Act – section 38 – budgetary authority and SGB decision-making; advertising of teacher vacancies pending resolution of budgetary/legal issues. * Civil procedure – application proceedings – where assertions are challenged in answering affidavit, applicant must plead or annex additional facts or documents to establish standing. * Evidence – disputes of fact on standing resolved on respondents' version where applicant fails to discharge evidentiary burden.
9 May 2023
Rescission refused: applicant failed to show error or good cause and advanced no prima facie defence.
* Civil procedure – rescission of default judgment – Uniform Rule 42(1)(a) – requirement that judgment be erroneously sought or granted in absence of affected party. * Civil procedure – rescission under common law – good cause requires reasonable explanation for default and bona fide defence with prima facie prospects. * Discovery non-compliance and striking of defence – consequences for defendant. * Costs follow result; negligent conduct of State Attorney fatal to rescission.
9 May 2023
Contingency fee agreements must strictly comply with the Act; non‑compliance renders them invalid and limits recoverable fees.
* Contingency Fees Act 66 of 1997 – strict compliance required with sections 2, 3 and 4; agreements must be with a legal practitioner and in prescribed form. * Section 4(1) – mandatory filing of affidavits and judicial approval before accepting settlement where matter is before court. * Non‑compliance – renders contingency fee agreement invalid; practitioner entitled only to reasonable fees assessed via taxation.
4 May 2023
Whether evasive manoeuvres in a sudden emergency constitute contributory negligence — court held none, awarding full liability and costs.
Road Accident Fund – negligence and contributory negligence – sudden emergency doctrine – evasive manoeuvres justified where oncoming vehicle overtook unsafely – apportionment under Apportionment of Damages Act – costs of two counsel allowed.
2 May 2023
Sentence set aside where trial court misdirected itself and imposed a disproportionate sentence for minimal involvement in stock theft.
Stock Theft Act – sentencing appeal – misdirection by trial court relying on extraneous material and over‑emphasis of prevalence; Zinn triad applied; mitigation (age, serious ill‑health, first offender, minimal role) – sentence substituted; Firearms Control Act s103 – erroneous declaration of unfitness to possess firearm.
2 May 2023
April 2023
25 April 2023
Where genuine disputes of fact exist, court accepted respondent’s version and dismissed applicant’s claim for return of vehicle.
Motion proceedings — disputes of fact — Plascon‑Evans rule; Motion vs oral evidence — failure to seek viva voce where disputes known; Agency/authority to bind owner — owner’s authorisation to daughter to agree retention of vehicle; Possession/retention of vehicle after collision; Costs following unsuccessful motion proceedings.
21 April 2023