High Court of South Africa Eastern Cape, Mthatha

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390 judgments
Citation
Judgment date
April 2023
Magistrate must dispatch Rule 53 record despite related filings; unnecessary opposition by another party attracts costs.
* Judicial review – Rule 53(b) – duty of presiding officer to dispatch record and reasons within 15 days of notice of motion. * Related proceedings – filing of same record elsewhere does not absolve separate Rule 53 obligations. * Costs – no costs against non‑opposing presiding officer; unnecessary opposition by an unrelated party attracts costs.
21 April 2023
March 2023
Appellants failed to show bail was in the interests of justice given a strong State case and likelihood of re-offending and witness interference.
Bail — Schedule 5 offences — onus on accused under s60(11)(b) to show interests of justice permit release — s60(4) factors: likelihood to commit Schedule 1 offence, evade trial, or intimidate witnesses — strength of State's case (documents, bank statements, receipts) — use of phones/WhatsApp and messages from custody as indicia of ongoing criminality — appellate review where court a quo misdirects in evaluation of facts.
28 March 2023
Interim interdict dismissed: urgency self-created and applicant failed to establish a prima facie right or irreparable harm.
Interim interdict — urgency — self-created delay; requirement of prima facie right (though open to some doubt); non-disclosure and bona fides; allegations of forgery/fraud require primary facts; Administration of Estates Act s18(3) — Master may issue letters of authority for small estates; alternative remedies (enrichment) may negate irreparable harm.
23 March 2023
Plaintiff failed to prove assault by a security guard on a balance of probabilities; appeal upheld and claim dismissed.
* Delict – alleged assault by security guard – onus to prove assault on balance of probabilities. * Evaluation of evidence – conflicting versions: credibility, reliability and probabilities. * Importance of contemporaneous medical records and corroboration. * Appellate review – requirement for trial court to make credibility findings when versions conflict.
22 March 2023
A default judgment for unliquidated damages requires viva voce evidence; the applicant's damages affidavits lack probative value.
Civil procedure – Default judgment – Unliquidated damages – Rule 31(2)(a) requires oral evidence; plaintiff "damages affidavits" lack probative value; expert medico-legal reports admissible by affidavit if authored and confirmed by qualified expert and linked to viva voce evidence; proper notice of set down required; misapplication of rules for liquidated or interlocutory matters discouraged.
17 March 2023
Police failed to prove self‑defence; shooting was unlawful and the State held liable for proven damages.
• Criminal/tortious liability of the State – police use of force – test for self‑defence and objective assessment of necessity and proportionality. • Onus on party pleading self‑defence – requirement to adduce credible evidence when versions conflict. • Adverse inference where an available witness with material evidence is not called by a party. • Evaluation of credibility, reliability and probabilities in resolving mutually destructive accounts.
14 March 2023
University's premature reallocation of an admitted student's space violated his constitutional right to further education and breached the admission contract.
* Constitutional law – Right to further education (s 29(1)(b)) – admitted applicant prevented from registering contrary to admission terms – unlawful denial of access to further education. * Contract law – Interpretation of admission letter – three‑day acceptance term constituted binding contractual term; offeror may not withdraw or reallocate before expiry. * Administrative/public institution obligations – transparency and accountability in application and registration processes; reliance on 'space availability' and 'first come first served' cannot override explicit acceptance timelines. * Evidence – respondent required to prove applicant’s acceptance was late; failure to do so defeats defence of late acceptance.
7 March 2023
Exception dismissed: particulars sufficiently plead alleged misuse of confidential-use licence and damages comply with Rule 18.
* Civil procedure – exception for vagueness and embarrassment – test under Rule 23; pleadings must identify cause of action with sufficient particularity. * Contract – interpretation on exception – reluctance to decide definitive meaning where surrounding evidence may be admissible. * Confidential information/licence – scope of use licence and alleged unauthorised use. * Rule 18 – damages pleaded as 30% of estimated project costs sufficiently particularised.
3 March 2023
Quantum in medical negligence: award for lost earnings, lifelong care and housing for disabled minor, with contingency deduction and trust protection.
Medical negligence — quantum assessment — future loss of earnings, lifelong care and domestic assistance, and accommodation adaptations for a child with cerebral palsy; weight of conflicting expert evidence; contingency deduction (sliding scale); trust to protect minor’s capital award; comprehensive costs order including costs of two counsel.
2 March 2023
February 2023
Hospital staff’s failure to monitor and intervene during labour caused intrapartum hypoxic-ischaemic brain injury and cerebral palsy.
Medical negligence – obstetric care – failure to plot partogram and adequately monitor CTG; delayed and inadequate response to persistent fetal heart abnormalities; failure to prepare/perform urgent caesarean section – causation of intrapartum hypoxic-ischaemic brain injury and cerebral palsy; evaluation of competing expert opinions and weight of incomplete clinical records.
28 February 2023
Court excluded confessions after probable police assault and discharged all accused for lack of admissible evidence.
Criminal procedure – admissibility of confessions (s217 CPA) and pointing out (s219A CPA) – voluntariness – reasonable possibility of police assault – exclusion of statements; Circumstantial evidence – Blom test – insufficiency after exclusion; Discharge under s174 CPA; Investigative practice – use of commissioned officers versus magistrates and need for sworn interpreters; Recommendation for procedural/legislative reform.
26 February 2023
Accused convicted of familicide; prescribed life sentences applied for murders and arson penalised, no substantial and compelling circumstances found.
* Sentencing – application of Zinn triad and Malgas guidance to Minimum Sentences Act. * Minimum Sentences Act s51(1) – life imprisonment ordinarily prescribed for listed murders. * Departure from prescribed sentence – requirement of substantial and compelling circumstances. * Aggravating factors – familicide, premeditation, child and pregnant victim, lack of remorse. * Firearms Control Act s103 – declaration of unfitness to possess firearms.
16 February 2023
Circumstantial and DNA evidence established that the accused intentionally burned and murdered four relatives.
* Criminal law – Arson and murder – Circumstantial evidence – Cumulative assessment of motive, opportunity, forensic and DNA evidence to establish guilt beyond reasonable doubt. * Forensic pathology – Burned bodies (100% burns) and presence of blood at scene indicating bleeding prior to burning. * DNA evidence – Deceased’s DNA on accused’s clothing; unknown male DNA on tracksuit pants; incomplete reference samples. * Criminal procedure – Discharge in terms of s174 appropriate for co-accused where evidence insufficient.
13 February 2023
Court imposed prescribed life imprisonment for rape of a six‑year‑old, finding no substantial and compelling circumstances to deviate.
Criminal law – Sentencing – Minimum sentence legislation – Rape of a child (six years) – Requirement to prove substantial and compelling circumstances to deviate from prescribed life imprisonment – Sentencing triad (crime, offender, society) – Aggravating factors: very young victim, forced penetration, injuries, hospitalisation, trauma, position of trust, lack of remorse.
3 February 2023
Reported
Plaintiff failed to prove the alleged defamatory accusation; court finds defendants reported suspicions and dismisses claim with costs.
Defamation — alleged publication during conference call — meaning and defamatory tendency — onus to prove publication — credibility of witnesses and contemporaneous documentary evidence — report of third‑party suspicions and investigatory communication as defence.
2 February 2023
High Court not first-instance forum for s111 disputes; respondent complied with s111(2)(a); application dismissed.
* National Credit Act – section 111(1) and (2)(a) – disputed account entries – what constitutes "reasonable detail" in a written response. * Jurisdiction – National Consumer Tribunal is primary forum for disputes under sections 111/115/134; High Court not forum of first instance. * Civil procedure – motion proceedings and Plascon-Evans rule – applicant bound by founding affidavit; disputed facts accepted on respondent’s version where appropriate. * Evidence – late demands for call logs/ATM number not part of pleaded dispute and do not vitiate compliance with s111(2)(a).
2 February 2023
January 2023
Complainant’s evidence corroborated by DNA and reliable chain‑of‑custody sufficed to convict the accused of raping a six‑year‑old.
Criminal law – Sexual offences – Rape of a minor; identification evidence via shouted name and in‑situ pointing; single child witness evaluated with caution but accepted where consistent and corroborated; forensic evidence (blood on sheet) and DNA matching; chain of custody of exhibits; accused’s alternative explanation rejected as inherently improbable.
27 January 2023
Application for emergency disaster accommodation dismissed for failure to exhaust remedies and to prove a disaster.
Administrative law – PAJA s6(2)(g) (mandamus) and s7(2)(a) (exhaustion of internal remedies); Disaster Management Act – definition, classification (s23) and declaration of local state of disaster (s55) – preconditions for municipal emergency powers; Principle of legality – limits where statutory preconditions not established; Joinder – improper joinder of provincial and district organs where no legal duty shown.
10 January 2023
December 2022
Employee contractual right to a written account and debatement of overtime cannot be denied by deferring to PAIA or internal review procedures.
* Labour law – employment contract – entitlement to written statement of account and debatement for overtime worked; contractual obligation to account. * Procedure – claim for account and debatement – requirements: right to account, contractual terms affecting amount, failure to render an account (Doyle test). * Access to information – PAIA/internal review not a prerequisite to litigating a contractual accounting claim.
13 December 2022
Court dismisses attempt to compel Premier to investigate; referral order binds the Commission, not the Premier.
* Administrative law – interpretation of court orders – referral to statutory commission v. executive discretion; * Traditional leadership law – repeal of Framework Act and commencement of Khoi‑San Act; * Section 59(2) Khoi‑San Act – discretionary power of Premier to designate investigative committee; * Section 65(2) Khoi‑San Act – saving/correspondence provision does not permit court to usurp discretion where no submission to Premier made; * Procedural – appropriate remedy is variation/amendment of order, not enforcement against non‑addressee; * Costs – unsuccessful, misdirected litigation against public office‑bearer attracts costs.
13 December 2022
Fourth applicant lacked standing; first and third disconnections lawful; application dismissed with costs against applicants.
Local government — electricity disconnection — lawfulness under Municipal credit-control policy and Electrical Installation Regulations; indigent-subsidy applications do not confer automatic entitlement pending approval; locus standi — residents' association must show authorisation or legal persona to sue; Plascon-Evans principle in motion proceedings; costs where litigation is abusive.
13 December 2022
Applicant's arrest and detention unlawful; malicious prosecution claim dismissed; R456,000 awarded for unlawful deprivation of liberty.
Unlawful arrest — s 40(1)(b) CPA — reasonable suspicion must be personally formed and based on reasonable grounds; arresting officer must consider and, where appropriate, investigate exculpatory alibi. Malicious prosecution — requires lack of reasonable and probable cause and animus; prosecutor's assessment of docket material can found reasonable and probable cause. Assessment of damages for unlawful arrest and detention — solatium, duration and conditions considered.
13 December 2022
Applicant failed to prove contempt; Rule Nisi interpreted narrowly and application dismissed with costs.
Contempt of court – requirements for contempt (existence of order, service/notice, non-compliance, wilful and mala fide) – Rule Nisi interpretation – lis pendens and discretion to stay proceedings – disputes of fact in motion proceedings requiring careful assessment.
8 December 2022
Second accused discharged for insufficient evidence; first accused must answer charges due to incriminating blood/DNA evidence.
Criminal procedure – s174 CPA – discharge at close of State case – Lubaxa standard – circumstantial evidence and forensic links (blood/DNA) may create a prima facie case; insufficiency of motive/suspicion alone warrants discharge.
2 December 2022
Applicant failed to prove authenticity of disputed liquor licence; urgent relief dismissed and respondents awarded costs.
Administrative law – Liquor licensing – Validity and authentication of disputed liquor trading licence – Plascon‑Evans application where applicant fails to dispute respondent's factual allegations – State Liability Act service requirements – purposive approach to statutory service – urgent relief burden and costs.
1 December 2022
Court granted final interdict protecting community’s site demarcation and ordered respondents to cease harassment and pay costs.
• Civil procedure – final interdict – requirements (clear right; injury or apprehension; no alternative remedy) – Setlogelo principle; • Evidence on motion – disputes of fact – Plascon-Evans and Wightman principles; • Customary/ traditional structures – joinder of traditional council – necessity requires direct and substantial interest; • Land/occupation rights – long-standing community occupation can ground protectable rights warranting injunctive relief; • Enforcement – court may authorise police assistance to sheriff.
1 December 2022
November 2022
Defendant failed to prove prescription; court refused remit for further evidence and dismissed the special plea.
Civil procedure – prescription – burden on defendant raising special plea to prove inception and completion dates and claimant’s knowledge; where facts lie within claimant’s knowledge defendant bears a reduced evidentiary burden but must still adduce evidence; parties’ agreement to separate issues must be respected; condonation under s 3 of the Act does not necessarily operate as res judicata.
29 November 2022
Condonation refused where Rule 30(2)(b) notice was defective, delays inadequately explained, and prospects of success absent.
Civil procedure – Rule 30 irregular proceedings – Requirement that a Rule 30(2)(b) notice must afford ten days to remove causes of complaint and warn of consequences – Rule 30(1) applications must be instituted within prescribed time – Condonation principles (Melane factors) – Attorney negligence and limits to relying on representatives’ delays – Prejudice and undue delay in minor child medical negligence claims.
22 November 2022
Appeal reinstated; default judgment not void ab origine, but illegal usurious interest corrected to prevailing legal rate.
Condonation — reinstatement of lapsed appeal; rescission of default judgment — Rule 49(1) (20-day rule) v Rule 49(8)/s36(1)(b) Magistrates’ Court Act; void ab origine — limited to no service/no mandate/no jurisdiction; magistrate’s discretion to accept affidavit evidence (rule 32(2)); prescribed/presiding rate of interest — illegal usurious interest corrected; costs allocation for condonation and abandoned application.
8 November 2022
October 2022
Non-compliance with court rules and delayed, uncondoned review of the Master’s appointment justified striking the application off the roll.
* Civil procedure – compliance with Uniform Rule 62 and Practice Directive – proper pagination, collation and annotation of papers required; non-compliance may justify striking matter off roll. * Administrative law – challenge to Master’s appointment of executor amounts to review under PAJA and is subject to rules against unreasonable delay and condonation. * Estates – Administration of Estates Act – appointment and removal of executors are powers of the Master; removal by court only on s54(1)(a) grounds. * Costs and sanctions – courts may sanction practitioners for persistent non-compliance, including striking matters and warning about fees.
20 October 2022
Rescission refused where applicant’s prolonged inaction and attorney negligence failed to justify setting aside dismissal.
* Civil procedure – Rescission of judgment – Uniform Rule 42(1) and common-law rescission – limits where judgment was procedurally competent and not erroneously granted. * Uniform Rule 30 – declaration of irregularity, leave to amend, and power to order dismissal if irregularity not removed. * Effect of dismissal – equivalent to absolution from the instance; plaintiff may in principle sue afresh. * Attorney negligence and client passivity – inadequate explanation for default; need for reasonable explanation and good prospects on merits for rescission.
18 October 2022
Leave to appeal refused where evidence supported conviction for assault with intent to do grievous bodily harm and sentence was appropriate.
Criminal law – Competent verdicts to murder – Assault with intent to do grievous bodily harm as competent verdict where assault forms part of actus reus of murder; common purpose liability; sufficiency of evidence without individualised identification; forensic pathology evidence; sentencing and deterrence in witchcraft‑related vigilante violence.
6 October 2022
September 2022
A mortgaged primary residence may be declared executable where debtor cannot show alternative means or disproportionate rights infringement.
* Civil procedure – Uniform Court Rule 46A – declaration of primary residence executable where mortgage bond and arrears exist; proportionality test and constitutional rights to property and housing. * Execution against mortgage security – efficacy and public confidence; refusal only where gross disproportionate infringement shown. * Suspension of execution – discretionary relief requires credible prospect of payment within reasonable time.
27 September 2022
Applicants lacked possession or clear right; interdict to prevent demolition or compel rebuilding was refused.
* Civil procedure – interim and final interdicts – requirements: prima facie/clear right, irreparable harm, balance of convenience. * Property – state land – occupation of vacant state land; absence of allocation or lawful possession. * Spoliation – mandament van spolie requires proof of prior peaceful and undisturbed possession. * Evidence – contemporaneous photographs can disprove asserted demolition or existence of structures. * PIE inapplicable where occupiers do not live on the land and are not in possession.
27 September 2022
Defendant liable for 105 days' unlawful detention; R500,000 awarded in general damages.
Unlawful arrest and detention – police liability for post-appearance detention – legal causation in remand cases – assessment of general damages for prolonged unlawful detention (105 days).
27 September 2022
The defendant unlawfully arrested, detained and shot the plaintiff; the State failed to justify the arrest or use of lethal force.
Police liability; unlawful arrest and detention — section 40(1) CPA — Schedule 1 jurisdictional requirement; use of force/private defence — necessity and proportionality; onus of proof on State; judgment at close of defendant’s case where defendant bears onus.
8 September 2022
A single breach can justify applying to operationalise a suspended sentence, but doing so prematurely risks unfair prejudice and must await finality.
Criminal procedure – Operationalisation of suspended sentence – Single breach suffices in principle, but application premature if subsequent conviction/sentence or appeal/review not finalised; proper procedure is to apply in the original suspended-sentence case after relevant milestones (S v Hoffman).
8 September 2022
Court found arrest, detention, assault and defamation by police unlawful; awarded R240,000 plus costs.
Police liability – unlawful arrest and detention – s 40(1)(b) CPA – credibility assessment of witnesses – assault supported by medical report – defamation and contumelia – quantum of damages.
4 September 2022
Applicant granted leave to amend particulars correcting location and commanding officer; amendment caused no prejudice or new cause of action.
* Civil procedure – Amendment of pleadings – Rule 28 – Delay in seeking amendment – prejudice must be shown – mala fides required to refuse. * Pleadings – Facta probanda – amendment of non-essential particulars (place and identity of commanding officer) does not introduce new cause of action. * Institution of Legal Proceedings Against Certain Organs of State Act – alleged conflict with statutory notice held without merit where facts corrected do not alter cause of action. * Prescription – amendment does not revive or create a new prescribed claim where essential cause remains unchanged.
1 September 2022
Application to review removal as headman dismissed due to res judicata and non‑compliance with PAJA time limits.
Administrative law – review – res judicata – prior dismissal of proceedings challenging same administrative decision precludes relitigation; PAJA – time limits – review launched outside 180‑day period without condonation; procedural fairness claims not addressed where preliminary objections dispose of matter.
1 September 2022
Review of headman removal dismissed for res judicata and failure to comply with PAJA time limits.
Administrative law – review of administrative decision – res judicata applies where identical decision previously challenged and dismissed; PAJA s.7 – 180‑day prescription; condonation requires adequate explanation for delay; merits of customary leadership claim not adjudicated.
1 September 2022
Refusal of bail upheld: appellant failed to show exceptional circumstances against a strong state case and risk to public peace.
Bail – s 60(4), s 60(11) and s 65 Criminal Procedure Act – exceptional circumstances – strength of state case assessed by circumstantial evidence – risk of disturbance to public peace – appellate de novo review restricted to evidence before court a quo.
1 September 2022
August 2022
Whether the applicant may evict unlawful occupants and whether the rectifying title transfer to the provincial government is valid.
* Property law – Eviction of unlawful occupiers from state-owned property; * Title rectification – validity of rectifying transfer to provincial government; * Delegation/donation of state land – chronology, registration and effect; * Administrative law – whether rectification/transfer constitutes administrative action (PAJA); * Prescription and acquisitive prescription; * Effect of spoliation orders on subsequent eviction proceedings.
23 August 2022
Court finds defendant liable for unlawful warrantless arrest and detention, awarding R95,000 plus interest and costs.
Police powers of arrest – Criminal Procedure Act s 40(1)(a) – requirements for warrantless arrest; Obstruction of justice – elements and application to speech; Freedom of expression as safeguard; Unlawful arrest/detention – damages assessment and interest.
18 August 2022
Subjective belief in witchcraft may be a substantial mitigating factor permitting departure from prescribed life sentences.
* Criminal law – Murder committed in furtherance of a common purpose – Minimum sentence under s51(1) and Part 1 of Schedule 2; * Sentencing – section 51(3)(a) substantial and compelling circumstances – subjective belief in witchcraft as mitigating factor; * Sentencing triad – consideration of seriousness, personal circumstances, deterrence and rehabilitation; * Convictions – murder, assault with intent to do grievous bodily harm, imputing witchcraft; * Sentence: effective 17 years for four murder-convicted accused; effective 5 years for accused convicted of assault and imputing witchcraft.
18 August 2022
Default judgment rescinded for failure to give required notice; applicants granted leave to file plea and each party to pay own costs.
Civil procedure – rescission of default judgment – rule 42(1)(a) – judgment erroneously sought/granted in absence of party – failure to give rule 31(5)(a) notice; condonation under rule 27 for failure to file plea – settlement negotiations and payment as good cause; costs — each party to pay own costs.
16 August 2022
Reported
High Court finds unilateral retrospective salary deductions unlawful; orders reinstatement and attorney-and-client costs.
Employment law – deductions from remuneration – Basic Conditions of Employment Act s 34 – requirement for law/agreement or fair procedure and hearing – High Court jurisdiction under s 77(3) BCEA – unlawful retrospective recovery of salary increments – declaratory relief and reinstatement ordered; costs on attorney-and-client scale.
16 August 2022
Identification assessed with caution; ballistic linkage and possession established guilt for robbery, murders and firearm offences.
* Criminal law – identification evidence – cautionary approach to eyewitness identification; credibility assessed against contemporaneous conduct and corroboration. * Forensic science – ballistic comparison – linking firearm recovered from accused to cartridge cases at crime scenes and to correctional-centre escape. * Criminal procedure – holistic assessment of circumstantial and direct evidence to determine guilt beyond reasonable doubt. * Conspiracy – merges with completed principal offence; separate conviction inappropriate when principal offence proved.
12 August 2022
Accused failed to show exceptional circumstances for bail where strong State case, prior convictions, flight and interference risks existed.
Bail — s 60(11)(a): accused facing possible life sentence must show exceptional circumstances; consideration of strength of State case, flight risk, witness interference, and prior convictions — magistrate entitled to prefer unchallenged investigating officer’s evidence — appeal against bail refusal dismissed.
10 August 2022
Applicant’s tender rejected for lacking separate indemnity certificate; court finds rejection lawful despite ambiguous wording.
* Procurement law – tender evaluation – key competencies – distinction between professional indemnity certificate and Fidelity Fund Certificate – requirement for separate indemnity cover upheld. * Administrative review – PAJA – challenge on grounds of irrationality, bias, irrelevant considerations and procedural unfairness – failure to show non‑compliance or reviewable defect. * Tender interpretation – ambiguity in bid documents – ambiguity noted but insufficient to invalidate employer's interpretation where separate requirements and scoring are evident.
2 August 2022