High Court of South Africa Eastern Cape, Mthatha

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390 judgments
Citation
Judgment date
August 2022
The respondent is vicariously liable for police omissions that caused the applicant’s loss.
Police duty of care – obligation to protect persons and property; omissions and negligence – standard of the reasonable police response; factual and legal causation – but-for and proximity analysis; vicarious liability of the State for SAPS employees; credibility assessment of witnesses; remedy – liability established, quantum to be determined.
2 August 2022
July 2022
Lease terminated; unlawful occupier evicted after PIE-compliant notice; claimed improvement lien inadequately proven.
Eviction under PIE – holding over/expiry of lease – one month’s notice sufficient; service of s4(2) notice effective despite delivery to domestic worker if occupier received and participated; ius retentionis (improvement lien) must be adequately pleaded and proved; absence of municipal relocation report not fatal where occupier is not destitute; organ of state entitled to regain control of immovable assets.
26 July 2022
Court orders extensive discovery under Rule 35(13) to examine former executor’s estate accounts and records.
Rule 35(13) — discovery in motion proceedings; exceptional circumstances where discovery may be directed; executor’s duty of uberrimae fides and obligation to account; relevance of liquidation and distribution accounts, bank statements, company documents and sale agreements; Master’s report not a substitute for discovery from a litigant.
26 July 2022
The applicant failed to prove valid acceptance of the permanent offer; leave to appeal denied under s17 'would differ' standard.
Employment law — contract formation — offer and acceptance — fixed‑term to permanent transition; requirement of written acceptance and proper delivery (annexure D6); post‑lapse indulgence and discretionary payments do not necessarily create contract; evaluation of evidence per Stellenbosch Farmers' Winery; leave to appeal threshold raised by s 17 Superior Courts Act — applicant must show another court would differ (Mont Chevaux).
26 July 2022
An unrepresented accused must be properly advised of counsel and adequately questioned under s112 or conviction will be set aside.
Criminal procedure – unrepresented accused – duty to explain right to legal representation and legal aid; Section 112(1)(b) – adequacy of questioning and requirement to cover essential elements; Section 113 – entering plea of not guilty when accused’s answers suggest defence; Contempt/contravention of protection order – necessity to prove unlawfulness and mens rea; Proof and service of protection orders; Delay in review and bail considerations.
26 July 2022
Accused convicted of robbery, three murders and firearm possession based on eyewitness ID and ballistic links; conspiracy and attempted murder failed.
* Criminal law – identification evidence – need for caution; assessing credibility and contemporaneous reporting. * Ballistics and chain of custody – firearm recovered from accused ballistically linked to cartridges at crime scene and earlier escape incident. * Unlawful possession of firearm – proven where firearm found on accused and linked to killings. * Conspiracy and premeditation – insufficient evidence; conspiracy merges with proved robbery and therefore falls away. * Attempted murder – conviction not supported where no evidence shots were fired at alleged victim.
19 July 2022
June 2022
Applicant failed to prove unlawful dispossession; he consented to police search and insurer’s possession lacked pleaded mala fides.
* Prescription/Delay – delay in launching spoliation claim and late joinder of insurer. * Property law – mandament van spolie – requirements of peaceful possession and unlawful deprivation. * Criminal Procedure Act s 22 – consent to search and seizure; lawfulness of seizure without warrant where consent or reasonable grounds exist. * National Road Traffic Act – provision on tampered VIN does not automatically oust spoliation remedy. * Joinder – insurer’s possession and lack of pleaded mala fides or nexus precludes relief against it.
21 June 2022
The accused were convicted of murder and imputing witchcraft; arson not proven; section 204 witnesses found credible.
Criminal law — murder — group assault and common purpose; imputation of witchcraft — s182 Act 9 of 1983; arson — insufficient proof; section 204 witnesses and video evidence — credibility and indemnity; medico‑legal cause of death — blunt force trauma and extensive burns.
17 June 2022
Leave to appeal refused: rescission justified by procedural/affidavit defects; SIU’s appeal notice failed Rule 49(1)(b).
* Civil procedure – rescission under Rule 42 – affidavit formalities and substantial compliance – defective affidavit and premature enrolment can justify rescission. * Civil procedure – discretion in rescission – court may exercise a discretionary power to rescind even where requirements met; must be exercised judicially (Zuma considered). * Civil procedure – mero motu setting aside – permissible where affected parties are before the court and the validity of earlier orders is squarely in issue. * Appeals – leave to appeal under s17(1)(a)(i) and (ii) Superior Courts Act – reasonable prospects and compelling circumstances required. * Appeals – Rule 49(1)(b) – grounds of appeal must be clear, succinct and identify findings challenged; non‑compliance justifies dismissal of leave to appeal. * Intervention – SIU locus standi – failure to identify errors or grounds for intervention fatal to leave to appeal.
14 June 2022
Unilateral suspension of NPO funding without due process is unlawful and must be reviewed and set aside.
* Administrative law – Section 33 Constitution – right to lawful, reasonable and procedurally fair administrative action; unilateral suspension of NPO funding; review and setting aside of administrative action. * Non‑Profit Organisations Act s3 – state duty to promote, support and enhance capacity of NPOs; duty engaged where funding withheld. * Constitutional rights – section 28 (best interests of the child) and section 29 (right to basic education) implicated where suspension adversely affects vulnerable beneficiaries. * Remedies – judicial review, setting aside of unlawful suspension and order for payment of arrear subsidies and costs.
14 June 2022
Whether a traditional leader can obtain an interdict preventing unlawful occupation of disputed communal land pending land claims.
Land law; communal/disputed land – interim relief to prevent unlawful occupation pending restitution; jurisdiction of High Court versus Land Claims Court; locus standi of traditional leader to protect communal lands; Plascon‑Evans principle in motion proceedings; requirements for final interdict (clear right, apprehension of injury, no alternative remedy); costs follow the event.
13 June 2022
May 2022
Respondent’s warrantless arrest lacked reasonable grounds; applicant awarded damages for unlawful arrest and detention.
Criminal procedure – Arrest without warrant (s 40(1)(b)) – Objective test of reasonable suspicion – Reliability of identification evidence – Unlawful detention after first appearance – Damages for unlawful arrest, detention and contumelia.
31 May 2022
Applicant failed to establish a clear right to justify a final interdict preventing entry or removal from the marital home.
Interdict – Final interdict requirements – clear right, apprehended injury, absence of alternative remedy; locus standi in relation to marital home; Rule Nisi – lapse not decided; costs following the event.
17 May 2022
Alleged promotion is an unfair labour practice; remedy must be sought under the LRA, not by declaratory relief.
* Labour law – unfair labour practice – promotion dispute – jurisdiction under the Labour Relations Act (s186(2)(a)); * Municipal employment – promotion and appointment prescripts; * Declaratory relief – absence of contractual cause of action and failure to prove valid promotion; * LRA remedy for LRA breach (Steenkamp principle).
17 May 2022
Condonation for late statutory notice denied where applicant had knowledge of the claim and delay was unexplained.
* Institution of Legal Proceedings Against Certain Organs of State Act 40 of 2002 s3 – requirement to give written notice within six months of knowledge of facts giving rise to debt; condonation under s3(4)(b). * Knowledge of cause of action – material facts (not legal conclusions) sufficient to start the notice period. * Condonation – necessity of full explanation for entire delay, prospects of success and absence of unreasonable prejudice. * Prescription – distinct from notice requirement; non‑extinction of debt does not obviate need to show good cause.
17 May 2022
Reported
Court dismissed appeal, holding internal Framework Act processes did not bar urgent declaratory and interdictory relief.
Traditional leadership – recognition of kingship – Framework Act (ss 9, 21, 25) – whether internal customary processes must be exhausted before court relief – Oudekraal principle and administrative acts – requisites for final interdict – urgency and costs (Biowatch principle).
6 May 2022
An interim rule nisi is not suspended by appeal; respondent must comply but was not immediately found in contempt due to reliance on legal advice.
* Civil contempt – elements: order, service/knowledge, non-compliance; presumption of wilfulness and mala fides – evidentiary burden on alleged contemnor. * Superior Courts Act s 18 – distinction between a ‘decision’ (final in effect) and interim/interlocutory orders; interim rule nisi not suspended pending appeal. * Urgency – contempt proceedings generally urgent but applicants must justify truncation of rule periods. * Costs – ordinary party-and-party costs appropriate where non-compliance may have stemmed from counsel’s erroneous advice. * Citation – Minister of Justice not a necessary party to civil contempt proceedings.
3 May 2022
April 2022
An employer may not withhold salary or treat a contract as terminated for unauthorised absence without notice and fair process.
Employment law – interpretation of termination clauses – clause 22(h) (unauthorised absence) does not operate as automatic termination without notice or application of HR/collective procedures; absence/leave without pay (clause 30) requires prior notice, opportunity to explain and proper accounting before salary may be withheld.
21 April 2022
Applicant unlawfully despoiled; spoliation and final interdict granted to restore possession and prevent further interference.
Property law — Mandament van spolie — Protection of possession and access as incident of possession; self-help dispossession unlawful even if arrear rent alleged; lien defence rejected absent contractual relationship; requirements for final interdict satisfied.
21 April 2022
March 2022
Confession excluded as not voluntary; State evidentially deficient — all accused discharged on all counts.
Criminal procedure — admissibility of confession — section 217 CPA; constitutional rights — section 35(1) — right to remain silent and legal representation; warning statement (SAPS) — necessity for early use; voluntariness of statements; sufficiency of circumstantial evidence; section 174 discharge.
24 March 2022
February 2019
Reported
Whether a magistrate’s reliance on a litigant’s attorney to rewrite a judgment breaches judicial independence and warrants review.
* Judicial misconduct – magistrate allowing litigant's attorney to rewrite reserved judgment – abdication of judicial function. * Constitutional principle – judicial independence and impartiality (s165) and right to fair hearing (s34). * Procedural fairness – delivery of reserved judgments and requirement of open court. * Remedies – review and setting aside of judgment, de novo trial, referral to Legal Practice Council, punitive costs.
14 February 2019
October 2015
High Court extended bail pending Constitutional Court appeal, finding inherent jurisdiction and arguable constitutional grounds (trial delay).
Criminal procedure; bail pending appeal — inherent jurisdiction of High Court to grant or extend bail where no appeal yet pending in Constitutional Court; functus officio not a bar where further appeal and constitutional grounds remain to be considered; section 321(1)(b) of Criminal Procedure Act does not oust inherent jurisdiction; unreasonable delay in prosecution as viable constitutional ground; assessment of flight risk and conditions of bail.
16 October 2015
September 2015
Knowledge of material facts, not of a legal remedy, triggers prescription; plaintiff’s unlawful arrest claim prescribed.
Prescription – Prescription Act 68 of 1969 s 12(3) – requirement of knowledge of debtor and material facts, not knowledge of legal remedy – unlawful arrest and detention claim prescribed.
23 September 2015
Whether a magistrate has jurisdiction under s 28(1)(d) depends on the material facts (facta probanda) constituting the cause of action.
Magistrates’ Court jurisdiction – s 28(1)(d) – "cause of action arose wholly within the district" – meaning of facta probanda vs facta probantia – place of offer/acceptance, lodging and repudiation of insurance claim determine jurisdiction.
15 September 2015
October 2014
Confession and pointing out reliably confirmed; convictions and life sentences for murder and housebreaking upheld.
Criminal law – Confession and pointing out – Admissibility and reliability – Section 209 CPA confirmation – Corrected recording errors and uninitialled amendments not fatal – Credibility assessment of accused’s evidence – Sentencing – Malgas guidelines – Life sentences appropriate where killing to prevent testimony and victims vulnerable.
30 October 2014
February 2014
Reported
The respondent’s summary judgment was set aside because the magistrate improperly condoned Rule non‑compliance.
Magistrates’ Court Rules — Rule 6(6) — failure to annex written contract — deemed irregular step under Rule 6(13); Rule 60/60A — scope — no general power of condonation to dispense with form or substance of rules; Summary judgment — Rule 14(1) — limited to specified categories; Affidavit in support — Rule 14(2) — ‘‘verify’’ means to swear positively to facts verifying cause and amount; Procedural fairness — irregularity to be remedied under Rules 60/60A, not condoned absent express rule or s54 conference.
27 February 2014
Reported
Court found provincial education authorities breached learners' right to basic education by failing to provide required school furniture and ordered prompt delivery.
* Education law – right to basic education (section 29(1)(a)) – immediately realisable right – provision of necessary resources including age and grade appropriate furniture. * Compliance with court orders – audit, verification and delivery plan – non-compliance of provincial education authorities. * Budgetary constraints – not a blanket defence to immediate obligations under section 29(1)(a). * Judicial remedies – supervisory jurisdiction; mandatory orders with fixed timeframes; conditional extension mechanism; costs order including two counsel.
20 February 2014
January 2014
Reported
Applicant failed to establish valid withdrawal or urgency; successor’s conditional recognition upheld and application dismissed with costs.
* Traditional leaders – Recognition and removal – Eastern Cape Traditional Leadership and Governance Act 4 of 2005 – Sections 18, 20 and 21 – identification, recognition, regency and removal. * Procedural law – Review of administrative decision – validity of royal-family withdrawal and requirement for proper customary process. * Acting/regent – cessation of acting role when identified successor attains majority. * Interdict – availability of statutory remedies and absence of irreparable harm. * Citizenship/residency – impact on eligibility under section 6(3) and conditional recognition.
30 January 2014
October 2013
Reported
A sale by a co‑owner can be contractually valid though transfer requires co‑owner cooperation; cancellation without contractual notice is invalid.
Property law; sale of res aliena – seller not sole owner; Alienation of Land Act s2(1) – formalities concern agents’ written authority not substantive ownership; Matrimonial Property Act s15(2) applies during marriage not post‑divorce; co‑ownership after divorce requires co‑operation for transfer; prior personal right gives claim to specific performance but equitable discretion and bona fide subsequent purchasers affect relief.
10 October 2013
September 2013
Two notices of intention to defend by State Attorney and correspondent are not per se irregular; prejudice must be shown to set them aside.
Civil procedure – Rule 19 and Rule 30(1) – State Attorney may employ correspondent – filing of two notices of intention to defend by State Attorney and correspondent not per se irregular – prejudice required to set aside procedural step – pending Rule 30(1) application suspends further pleadings.
26 September 2013
"Institute action" in a time-limited order is satisfied by issuing summons, not by effecting service.
* Civil procedure – interpretation of court orders – meaning of "institute action" – issue of summons constitutes institution of action, not service; * Where language is clear, order must be construed from its terms; extrinsic evidence only if ambiguity; * Authorities considered: Labuschagne, Mati, Himmelsein, Msomi.
26 September 2013
Failure to inform and record arrestee's constitutional rights rendered an otherwise contested arrest unlawful.
Criminal procedure — Arrest — s40(1)(a) Criminal Procedure Act; Road traffic offence — s12 National Road Traffic Act; Standing Order G341 — duty to inform arrestee of constitutional rights and to record same; non-compliance with procedural safeguards may render arrest unlawful; assessment of credibility and duration of detention.
6 September 2013
August 2013
Urgent interdict dismissed: applicants lacked locus and entitlement; punitive de bonis propriis attorney-and-client costs ordered.
Procedure – Urgent applications – duty of attorneys to enroll and prepare indexed papers; Company law – deregistration extinguishes company’s legal personality and locus standi; Interim relief – requirements for interdict (clear or prima facie right, reasonable apprehension of irreparable injury) not established; Rule 14 inapplicable to deregistered companies; Costs – de bonis propriis and punitive attorney-and-client costs justified where litigation is misleading, frivolous or negligently conducted.
29 August 2013
Court granted urgent interim relief: sale lapsed, lease terminated, and tenants ordered to pay rent to the owner pending finalisation.
Urgency — Rule 6(12) — assessment of founding affidavit and inherent probabilities; Contract — suspensive condition — sale agreement rendered null by non‑fulfilment and absence of written extension; Lease — month‑to‑month tenancy terminated by notice — unlawful occupation; Subleases — a sub‑lessee cannot acquire greater rights than a lessee — relief to regularise rent payments; Pleadings — authority to depose may be proved in replying affidavit.
7 August 2013
March 2013
Plaintiff’s claim prescribed because prescription began when he learned of the CCMA ruling; correspondence did not interrupt prescription.
Prescription — when prescription begins to run; creditor must have minimum facts to institute action (Truter v Deysel principles); interruption of prescription by acknowledgment (s 14) requires express or tacit admission; correspondence not amounting to written admission does not interrupt prescription.
7 March 2013
September 2011
A public‑sector dismissal governed by the LRA and collective agreements is a labour matter, not administrative action under PAJA, and is dismissed.}
* Labour law – public-sector dismissal – whether termination of employment by an organ of state constitutes administrative action under s 33/PAJA – held not to be administrative where governed by LRA and collective agreements. * Jurisdiction – collective bargaining agreement (GPSSBC) dispute-resolution procedures require referral for conciliation/arbitration; High Court review under PAJA inappropriate. * Procedural irregularities in disciplinary hearings are labour matters to be pursued via LRA mechanisms, not PAJA review.
23 September 2011
August 2011
Sale and transfers of property forming part of a joint estate, made without the spouse's consent, are voidable and set aside.
* Matrimonial property – marriage in community of property – property acquired during marriage forms part of joint estate – alienation requires written consent of non-contracting spouse (Matrimonial Property Act s15(2)). * Deeds and transfers – third parties must take reasonable steps to ascertain marital status and consent before registering transfers. * Invalid transactions – sales and transfers effected without required consent are wrongful, irregular and may be set aside. * Marriage law – Transkei Marriage Act inapplicable to marriage solemnised in 1999 outside former Transkei; universal community of property applies. * Costs and conduct – poor record-keeping and abuse of process by legal representatives may attract adverse costs consequences.
18 August 2011
April 2011
Mere foresight and membership of a group do not suffice for common‑purpose murder; active association or prior agreement required.
Criminal law – Common purpose – Distinction between liability based on prior agreement and liability based on active association – Requirements in absence of prior agreement per S v Mgedezi/S v Safatsa – Constitutional approval in S v Thebus – Limited continuing application of S v Nzo’s broader foresight-based approach; mere foresight insufficient without active association.
28 April 2011
Temporary disability grants lapse by law; non-notification does not entitle continued payment or review.
Social assistance — disability grants — temporary grants lapse by operation of law under reg 28(1)(d) and are not termination decisions reviewable under PAJA; failure to notify under reg 13(3)(d) does not of itself create a substantive legitimate expectation of continued payment; distinguishing Mdodisa/Joni and Mpofu; Plascon‑Evans rule and Rule 6(5)(g) application.
7 April 2011
March 2011
A public body’s unexplained silence to a PAIA request does not bar court relief; punitive costs awarded for obstructive conduct.
* Promotion of Access to Information Act – internal remedies and section 27 (deemed refusal) – whether requester must exhaust internal appeal before litigation.* Constitutional right of access to information – obligations of public bodies to respond transparently and without undue delay.* Administrative law – courts’ role when public authorities fail to engage or communicate decisions.* Costs – punitive attorney-and-client costs where public body’s conduct is unconscionable.
18 March 2011