High Court of South Africa Eastern Cape, Port Elizabeth - 2022

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47 judgments
Citation
Judgment date
December 2022
An urgent interdict was granted preventing the Treasury from withholding a municipality's equitable share pending review.
Local government funding – equitable share – s214 Constitution and Division of Revenue Act – withholding of allocations; Interdict – requirements for interlocutory interdict; Urgency – condonation of non‑compliance with filing rules; Intergovernmental Relations Framework Act – s40 dispute invoked, no requirement to exhaust further s41 procedures before court; Review – rationality and lawfulness of administrative decision to withhold funds; Costs against state respondents including two counsel.
30 December 2022
Condonation refused and arbitration award upheld: arbitrator acted within powers and no gross irregularity proven.
Arbitration — Review of award — s 33(1) Arbitration Act — allegation of arbitrator exceeding powers or gross irregularity — misconduct threshold. Condonation — interests of justice — extent and cause of delay, prospects of success. Construction contracts — JBCC PBA — clause 26 (assessment/notice/determination) — submissions v evidence.
13 December 2022
Executor successfully obtained urgent mandament van spolie; PIE inapplicable because respondents did not occupy the property as their home.
Property law – mandament van spolie – requirements: prior peaceful possession and unlawful dispossession; restoration of possession. Urgency – spoliation proceedings as a speedy remedy; applicant’s prompt action and respondents’ acquiescence. Locus standi – executor’s authority to vindicate estate assets and sue on behalf of the estate. PIE – applicability limited to occupiers’ homes; PIE not engaged where occupiers do not use property as their home. Defence of abandonment – requires intention to abandon; mere absence or untidiness insufficient.
13 December 2022
Payment by a medical scheme does not absolve the Road Accident Fund from compensating admitted past medical expenses.
Road Accident Fund – past medical expenses – payments made by medical scheme – whether such payments must be deducted from RAF compensation – collateral benefits and double compensation – insurance nature of medical schemes – statutory interpretation of s18 RAF Act – subrogation/reimbursement rights of medical schemes.
1 December 2022
November 2022
Leave to appeal granted where another court may reasonably find differently on scope of duty of care and expert evidence.
Civil procedure – Application for leave to appeal – s 17(1)(a)(i) Superior Courts Act – reasonable prospects of success required, not certainty. Delict – Duty of care – scope of duty where defendant admits legal duty – effect on wrongfulness enquiry and negligence proof. Evidence – Expert conveyancer evidence – admissibility and weight where duty scope contested.
22 November 2022
Rescission refused — quantum properly determined on actuarial evidence; applicant failed to justify default.
Civil procedure – rescission of judgment – rule 42(1)(a) – whether order erroneously sought or granted in defendant's absence. Pleadings – rule 22(3) – distinction between admission and non-admission; non-admission may operate as denial where defendant lacks knowledge. Evidence – quantum of patrimonial loss – actuarial evidence may suffice; viva voce evidence of claimant not always required. Common law rescission – requirements: reasonable explanation for default, bona fides, and prima facie defence with prospects of success.
15 November 2022
Final interdict refused: applicant failed to show clear right and respondent raised a plausible truth/public‑interest defence.
Civil procedure – urgent applications – compliance with urgency rules and requirement to disclose material facts. Defamation – interlocutory/final interdicts restraining publication – Plascon‑Evans approach; need to show clear right and absence of viable defence (truth/public interest/fair comment). Harassment/extortion/compounding – distinction between lawful pressure to enforce a bona fide claim and unlawful extortion/compounding; requirements not established on papers. Corporate v personal reputation – communications directed at a company’s CEO are not automatically attributable to the company for interdict purposes. Remedies – final restraining orders against publication are granted infrequently; damages often adequate remedy.
8 November 2022
Court compelled further particulars and Rule 35 discovery for loss-of-rental claim, limiting scope to two years.
Civil procedure – Rule 21 further particulars – party entitled to particulars that are reasonably necessary to prepare for trial; court has discretion to grant relief where opposing party fails to give cogent reasons for refusal. Civil procedure – Rule 35(3) discovery – relevance test: documents which may directly or indirectly advance applicant’s case or damage adversary’s case (Compagnie Financiere/Brett LJ; Swissborough). "Fishing expedition" objection insufficient without demonstration of irrelevance or undue burden. Temporal scope of disclosure – excessive periods may be limited; two years either side of incident held reasonable. Failure to comply – leave granted to approach court on same papers for dismissal; costs follow result.
1 November 2022
Failure to provide sufficiently specific reasons and documents vitiated a s71 director removal; court reinstated the applicant.
Companies Act s71 — removal of director; statutory safeguards: notice, copy of proposed resolution and reasons with sufficient specificity; entitlement to particulars and documents; scope of s71(5) review — wide/full reconsideration; procedural fairness and remedial relief (reinstatement and record amendment).
1 November 2022
October 2022
High Court refuses piecemeal intervention; fraud and forgery charges found sufficiently particular, mandamus refused.
Criminal procedure – review in medias res – High Court intervention in unterminated magistrates’ court proceedings is exceptional and reserved for gross irregularity or grave injustice. Right to a fair trial – accused must be informed of charge with sufficient detail (s35(3)(a) Constitution; s84 CPA). Particularity of charges – a charge sheet read with preamble and further particulars must set out essential elements; unknown particulars may be so stated under s84(2). Forgery/fraud – where the charge sheet unambiguously alleges personal liability, the prosecution’s present inability to identify the actual forger does not necessarily render the charge defective. Mandamus – not appropriate absent demonstration of irremediable prejudice or necessity for immediate intervention.
31 October 2022
The insurer was not bound by its initial repudiation reasons and could require specialist confirmation before paying the impairment claim.
Insurance law; Policyholder Protection Rules – timing and applicability of PPR 17.6.3; fair treatment (PPR 1.4(f)) does not preclude insurer requesting further reasonable evidence; insurer entitled to require specialist confirmation of treating-doctor reports; repudiation reasons not frozen where rules post-date decision; requirement to cooperate with independent medical assessment.
31 October 2022
Applicant awarded maintenance and half of accrual via respondent’s pension; respondent ordered to pay child and spousal maintenance.
Family law – divorce – accrual claim – payment from pension interest – division of accrual via Massmart Provident Fund; Spousal maintenance – assessment of existing and prospective means, earning capacity and duration; Child maintenance – monthly contribution, medical scheme retention and payment of scholastic expenses; Consideration of historic bonuses when assessing prospective means.
18 October 2022
Facts that existed earlier but were inaccessible can be "new facts" permitting a renewed bail application; matter remitted for rehearing.
Bail on new facts — definition of "new facts" — facts or evidence existing previously but unavailable may be "new" where circumstances change; Schedule 6 offences — section 60(11)(a) exceptional circumstances; procedure on re-opening bail application and remittal to magistrate.
4 October 2022
Medical scheme payments do not extinguish the defendant’s obligation; subrogation/undertaking preserve the plaintiff’s claim.
Road Accident Fund — past medical expenses — effect of medical scheme payments — reimbursement undertaking and subrogation — scheme’s election to sue member or defendant — subrogation as procedural device — plaintiff may sue in own name where defendant not prejudiced.
4 October 2022
September 2022
Municipality liable for injuries from an uncovered storm-water drain; plaintiff found contributory negligent and awarded 90% of damages.
Municipal liability – duty to maintain and secure storm-water drains; omissions and wrongfulness; foreseeability and reasonable steps to prevent harm; single-witness evidence and assessment on probabilities; contributory negligence and apportionment of damages.
27 September 2022
An organ of state’s procurement decision is administrative action and remains effective until judicially set aside, precluding damages claims.
Administrative law – procurement by organ of state – procurement decision as administrative action – unlawful administrative act remains effective until set aside – plaintiff required to seek review (PAJA/principle of legality) before claiming damages – special pleas upheld.
27 September 2022
The applicant (executrix) obtained spoliation relief and mandamus compelling transfer after a valid but unregistered 2003 sale.
Property law – mandamentum van spolie – requirements: peaceful possession and unlawful dispossession established.* Succession/estates – executrix entitled to vindicate estate property and seek transfer despite unregistered transfer.* Specific performance/mandamus – compelling parties to sign transfer documents to effect registration into estate.* Contract law – validity of sale where purchase price largely paid but transfer not registered; absence of written variation or lawful cancellation.* Procedure – joinder and Rule 6(9) Master report not required; alleged disputes of fact did not preclude determination on affidavits.
16 September 2022
Leave to appeal refused: urgency rulings are not appealable and the appeal lacked reasonable prospects.
Urgency – Rule 6(12)(a) – Determination of urgency is a procedural case-management ruling and generally not appealable; Leave to appeal – s17(1) Superior Courts Act – test of reasonable prospects of success or other compelling reason; Service of process – failure to serve a party considered but not determinative; Suspension effect of leave to appeal application.
15 September 2022
A municipal manager must make basic enquiries and afford a chance to respond before treating a party’s expulsion as creating a vacancy.
Local government — proportional-representation councillors — s 27(c) MSA — effect of party notification of termination of membership — municipal manager and IEC must apply mind and make basic enquiries before declaring vacancy; administrative action reviewable; urgency and interlocutory variation where meeting adjourned.
15 September 2022
The plaintiff must pay wasted costs for a late postponement caused by an overseas witness's untimely unavailability.
Civil procedure — postponement of trial — wasted costs — party responsible for postponement ordinarily liable — virtual testimony requests — force majeure/COVID-19 — court's discretion to award costs.
13 September 2022
Application for leave to appeal dismissed; no reasonable prospects or compelling reasons on joinder, pleading and contractor liability issues.
Civil procedure — Leave to appeal — section 17 Superior Courts Act — reasonable prospects of success required for leave; Joinder — non-joinder and misjoinder — necessity requires direct and substantial legal interest; Pleadings — use of "and/or" acceptable when read in ordinary grammatical meaning and clarified by particulars; Delict — liability for harm despite appointment of independent contractor — Chartaprops principle requires more than mere appointment; Appellate discretion — no compelling reason to hear appeal where issues turn on facts and established authority.
8 September 2022
Court deviated from prescribed minimum sentences due to substantial and compelling circumstances, imposing lengthy determinate terms.
Criminal law – Sentencing – Application of prescribed minimum sentences (s 51 Act 105 of 1997) – Whether substantial and compelling circumstances exist to justify deviation – Consideration of age, pre-trial detention, first-offender status, role in offence and prospects of rehabilitation; Criminal law – Common purpose liability – conviction for murder of fellow perpetrator killed by police during exchange of fire; Robbery with aggravating circumstances – planning, use of firearms and public danger during pursuit.
7 September 2022
Applicant failed to show good cause for condonation: evidence not placed before court, rights were signed for, and delay was unexplained.
Institution of Legal Proceedings Against Certain Organs of State Act 40 of 2002 – s3(4) – condonation – "good cause" and prospects of success requirement. Leave to appeal – whether appeal has reasonable prospect of success. Evidentiary requirement – failure to place statements/docket before court. Arrest procedure – signing of notice of rights and effect on contention that constitutional rights were not read. Procedural delay – requirement to explain discrete six‑month periods for condonation.
6 September 2022
Hospital staff negligently failed to sedate, titrate and monitor a patient with delirium tremens, causing his fatal fall.
Medical negligence – failure to titrate sedative medication and inadequate monitoring of delirium tremens – expert opinion preference where founded on common‑cause hospital records – but‑for causation of hospital fall and death.
1 September 2022
August 2022
Applicant’s urgent s18 relief granted to implement transfer order pending appeal; cancellation of intermediary agreement effective 1 September 2021.
Insurance law — intermediary agreements and Master Policy — cancellation and effect on members; Superior Courts Act s18 — exceptional circumstances, irreparable harm and prospects of success; statutory change to definition of ‘group’ under Insurance Act — effect on transfer of book; non‑joinder — necessity of joining individual policyholders for provisional implementation of order.
30 August 2022
Court rescinded interlocutory separation order because confidentiality, misappropriation and damages issues were too intertwined to be tried separately.
Interlocutory procedure – separation order under Uniform Rule 33(4) – court may revisit/rescind interlocutory orders; convenience of severance – issues of confidentiality, misappropriation and unlawful use so interrelated that separate determination impractical; evidentiary and credibility overlap; costs of rescission to be costs in the action.
30 August 2022
Whether the particulars disclose a cause of action or are vague and embarrassing, and whether the claim is contract or delict.
Civil procedure – Exception to particulars – whether particulars disclose cause of action – vagueness and embarrassment – duty to plead material contractual terms and elements of delict. Contract v delict – relationship indicated a contract of services; claims must be pleaded in alternative and material terms and breach identified. Delict – wrongfulness and legal duty must be pleaded where pure economic loss is claimed; statutory inspection obligations and basis for liability must be pleaded.
16 August 2022
The plaintiff’s unchallenged evidence established a slip on a wet court floor; defendants’ mere appointment of a contractor did not discharge their duty, so both are jointly liable.
Premises liability – duty to keep premises reasonably safe – appointment of independent contractor does not absolve principal where reasonable steps to guard against foreseeable danger were not taken – application of Langley Fox test to slip-and-fall on wet floor – non-joinder/misjoinder of contractor insufficient to defeat plaintiff’s claim.
12 August 2022
Court enforces JBCC adjudicator’s monetary determinations, rejecting respondent’s set-off and impossibility defences and ordering payment.
Construction law – JBCC adjudication – enforceability of adjudicator’s determinations pending arbitration; set-off requires liquidated debts; specific performance of adjudicator’s monetary awards; role of termination finding in withholding payments.
10 August 2022
Political/contract appointee terminated for misconduct; MOA governed termination, collective agreement inapplicable, application dismissed with costs.
Administrative law – authority of municipal representatives and Rule 7 challenges to deponents/attorneys; Urgency – financial prejudice and non‑self‑created urgency can justify urgent relief; Employment law – distinction between political/contract appointments and permanent municipal employees; applicability of Collective Agreement and municipal Codes; Contract law – enforcement and cure of notice defects under a Memorandum of Agreement; Misconduct – threatening/aggressive conduct by a political appointee can justify summary termination under contract provisions.
5 August 2022
July 2022
Both applications dismissed as neither party established locus standi; each party to pay their own costs.
Civil procedure – locus standi – enforcement of restraint of trade agreements – standing of a party to an agreement – costs where both applications dismissed for lack of standing.
26 July 2022
Provisional winding-up refused because the company bona fide and reasonably disputed the alleged debt and share ownership.
Company law – provisional winding-up – inability to pay debts – winding-up inappropriate where debt is bona fide and reasonably disputed (Badenhorst; Kalil) – suspensive condition in share sale agreement – locus standi – set-off and prescription – just and equitable considerations.
26 July 2022
The respondent's contractual termination of the applicant's accounts for reputational risk is not reviewable under PAJA.
Banking law – termination of bank accounts – private contractual termination – not administrative action – PAJA inapplicable. Contract law – implied/tacit terms – good faith and audi alteram partem arguments; remedy for wrongful termination is contractual, not review. Judicial review – limits on review of private-party contractual cancellations; bona fide commercial decisions to protect reputation ordinarily not reviewable. Interim interdict – requirement of prima facie right and prospects of success; absence of same defeats interim relief.
19 July 2022
June 2022
Applicants failed to prove confidentiality or urgency; interim restraint would unduly restrict respondents' freedom to trade.
Interim interdicts – prerequisites: prima facie right, apprehension of irreparable harm, balance of convenience, no adequate remedy. Confidential information – must be useful, not public, and of economic value; client lists and standardised pricing may not be confidential. Employee mobility – absent reasonable restraint, ex-employee may canvass former clients; information memorised is not per se protected. Freedom of trade – interim restraints that effectively prevent trade may be contrary to public policy.
28 June 2022
Leave to appeal refused; applicant failed to show reasonable prospects on factual negligence and causation issues.
Medical negligence; birth injury – factual causation – fundal pressure alleged; evidentiary weight of caput and episiotomy; resuscitation and aggravation of intrapartum hypoxic-ischaemic injury; expert evidence and reliance on medical literature; leave to appeal – reasonable prospects required under s17(1)(a)(i).
17 June 2022
Customary practices cannot shield perpetrators from criminal liability for child trafficking, forced marriage, and rape under statutory law.
Prevention and Combating of Trafficking in Persons Act – forced marriage – child trafficking – rape – customary law – cultural practices not a defence – consent by minor invalid – statutory protection of children paramount – mens rea and knowledge of unlawfulness.
13 June 2022
May 2022
Persistent non-payment justified lawful termination of the lease and eviction; ADR was not invoked by the tenant.
Lease law – non-payment of rent; breach and cancellation of lease; call-up of security deposit; alternative dispute resolution clause not invoked; eviction; pacta sunt servanda; court’s discretion on period to vacate.
31 May 2022
An exception for vagueness must attack the whole cause of action; lack of particularity alone merits particulars, not exception.
Civil procedure — Exception for vagueness and embarrassment — rule 23(1) — exception must attack whole cause of action, not individual paragraphs. Pleadings — Particularity — mere lack of detail remedied by rule 18/read with rule 30 or by pleading and discovery, not by rule 23 exception. Defamation — essentials (publication, identification, extent of dissemination) must be pleaded; particulars read as a whole may be sufficient.
26 May 2022
Leave to appeal refused; applicants' speculative bid for confidential s417 inquiry papers denied and costs awarded.
Companies Act s 417 inquiry — confidentiality of inquiry materials; access to founding papers by prospective examinees; locus standi to challenge inquiry; speculative allegations of non-disclosure; balancing applicants' rights against the inquiry's purpose and liquidators' representations.
24 May 2022
Summary judgment granted where surety failed to disclose a bona fide, factually supported defence to indebtedness.
Summary judgment — suretyship — bona fide defence — undue influence allegations must be particularised — National Credit Act applicability to large agreements — suretyship clause valid if parties identifiable ex facie document; s6 General Law Amendment Act compliance.
19 May 2022
Whether virtually commissioned, electronically signed affidavits satisfy Regulation 3(1) and may be admitted as substantially complying.
Commissions of oaths – meaning of 'in the presence of' – physical proximity required; Electronic Communications and Transactions Act – recognition of electronic signatures and data messages; Regulations governing oaths are directory – doctrine of substantial compliance; judicial restraint – policy and territoriality questions for legislature or Minister; admission of virtually commissioned affidavits in interests of justice where purposes of regulation met.
5 May 2022
Supermarket liable where employees failed to detect and clean foreseeable flour spillage causing shopper’s fall.
Delict — Occupier’s/retailer’s duty to keep premises reasonably safe for shoppers; obligation to discover and remove spillages promptly. Wrongfulness of omission — legal duty to act positively where it is reasonable to expect preventive measures. Negligence — foreseeability and reasonable steps (Kruger v Coetzee test) applied to supermarket spillages. Evidence — CCTV and witness concessions support inference of spillage from unpacked flour sacks. Contributory negligence — raised but not pursued; no apportionment on the evidence.
5 May 2022
Arrest and detention held unlawful where officer lacked reasonable suspicion of a Schedule 1 offence and failed to investigate available exculpatory information.
Arrest without warrant; s40(1)(b) Criminal Procedure Act 51 of 1977; Schedule 1 offences; reasonable suspicion; obligation to consider information reasonably available (including exculpatory explanations); duty to investigate where reasonable; unlawful arrest and detention; damages and costs.
3 May 2022
April 2022
Municipal consultant appointment breached SCM rules; payments were irregular expenditure recoverable from officials under s32 MFMA.
Municipal procurement – breach of SCM policy and MFMA – appointment without competitive process – payments constituted irregular expenditure recoverable under s32(1)(c) MFMA; Accounting officer and senior officials’ liability for irregular expenditure; Common‑law duties of employees to employer – liability for negligent or intentional breaches; Delay plea and constitutional challenge ineffective where not pleaded and where s32 recovery not time‑barred.
26 April 2022
26 April 2022
Executive Mayor’s summary dismissal of a s56 senior manager was unlawful; dismissal set aside and costs awarded on a punitive scale.
Municipal law – Local Government: Municipal Systems Act s 56 – senior managers – authority to discipline and dismiss vested in municipal council; Disciplinary Regulations for Senior Managers governing process. Administrative law – principle of legality – summary dismissal without statutory process unlawful. Delegation – doubtful that executive mayor may exercise council’s disciplinary powers; cannot be delegated to authorize unlawful acts. Urgency – court may grant urgent relief where conduct is manifestly unlawful and prejudicial. Costs – egregious unlawful conduct may attract punitive costs, but personal costs require a finding of mala fides.
12 April 2022
A municipality cannot sue its own council; interim relief refused for lack of prima facie right and irreparable harm.
Local government — legal personality and standing — municipality acts through municipal council; procedural law — interim interdict — requirements: prima facie right and irreparable harm; municipal procedure — quorum and lawfulness of council meetings; joinder issues; alternative remedy — s 59 Systems Act review by council.
5 April 2022