High Court of South Africa Eastern Cape, Port Elizabeth - 2023 February

10 judgments
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10 judgments
Citation
Judgment date
February 2023
Court confirmed sale to highest bidder after open-court Rule 46A reconsideration; property was not primary residence.
Rule 46A – reserve price reconsideration where reserve not achieved; mandatory open-court reconsideration; application of Rule 46A(9)(b) factors (market/forced-sale value, rates, occupancy, likelihood of sale); confirmation of sale to highest bidder under Rule 46A(9)(e); distinction between primary residence protection and investment property.
28 February 2023
Court removed the applicant as trustee for dereliction, struck out affidavit material and appointed new trustees to restore trust administration.
Trust law – Removal of trustees – s20(1) Trust Property Control Act – court may remove trustee in interests of trust where dysfunction or dereliction imperils trust; fiduciary duties – trustees’ duty of care and avoidance of conflicts; evidence – striking out hearsay and scandalous/vexatious affidavit material for non-disclosure of source; appointment – court’s power to appoint/substitute trustees and to appoint multiple independent trustees notwithstanding deed wording.
21 February 2023
Rescission of a consent order for municipal debt failed for lack of a common mistake and causal connection.
Rule 42(1)(c) — rescission for common mistake; municipal indebtedness and consent orders; threat to interrupt electricity supply; applicability of Resilient; causation requirement for setting aside consent judgments; finality of court orders vs. IRFA dispute resolution.
14 February 2023
Warrant valid where State Liability Act steps complied with and incorrect case number was an inconsequential clerical error.
State Liability Act (Act 20 of 1957) s3(3)–(6) – compliance required before execution; warrant of execution – clerical error in case number – bona fide, inconsequential mistake not vitiating writ; requirement of prejudice/materiality to set aside writ; locus to prosecute claim against sheriff where applicant has no interest in remaining issue.
14 February 2023
Consolidation refused: distinct issues and substantial prejudice (delay and costs) to the respondent.
Rule 11 – Consolidation of actions; convenience to court and parties; avoidance of multiplicity and costs; prejudice and delay; distinct issues of agency/settlement agreement v insurer repudiation and indemnity; different witnesses and evidence required.
14 February 2023
Minor claimant found unemployable; future loss of earning capacity awarded with 25% contingency deduction.
Road Accident Fund – quantum – future loss of earning capacity of a child pedestrian – severe orthopaedic injury, chronic pain and compromised post‑morbid intellectual functioning – expert evidence evaluation (orthopaedic, occupational, educational and industrial psychology) – actuarial valuation accepted – 25% contingency deduction applied – unemployability established.
10 February 2023
Executrix’s possessory right supports spoliation relief; ordering compelled transfer may have been premature, leave to appeal granted on that point.
Civil procedure — mandament van spolie — possessory relief available to an executrix who has detentio and animus in respect of estate property when forcibly dispossessed. Administration of Estates Act — executor’s duty and rights to take control of deceased’s property and to enforce enforceable contracts entered into by the deceased. Joinder — non‑joinder of the Master not fatal to urgent spoliation proceedings where Master’s input is unnecessary. Remedies — self‑help by alleged owners impermissible; estate and interested parties must pursue claims under the Act or in court. Competence of relief — court may have been premature in ordering compelled signature of transfer documents before estate administration steps completed.
9 February 2023
A court may refuse to enforce a termination-on-notice clause used mala fide to evade a court order.
Contract law – enforcement of termination-on-notice clauses – pacta sunt servanda not absolute – mala fide enforcement contrary to public policy – will not be enforced where used to undermine court orders; interim relief to suspend such enforcement where urgency, prima facie right and balance of convenience established.
7 February 2023
Employer’s inadequate line-specific training and supervision caused employee’s back injury; defendant held liable.
Delict — negligence: employer/occupier duty to provide adequate line-specific training and supervision for hazardous machinery; failure to train/supervise operators on SSB rear-axle line; factual and legal causation established (sine qua non and foreseeability); admissible expert occupational-therapy evidence on mechanism of injury; costs including expert fees awarded.
6 February 2023
Medical aid payments do not bar RAF liability for proven past medical expenses, particularly for a child claimant.
Road Accident Fund liability – past medical and hospital expenses – whether medical aid payments reduce RAF liability – admissions and agreed quantum determinative. Personal payment requirement – minors and dependents – payments by parent/medical aid do not preclude recovery. Interpretation of RAF Act – no statutory basis to deny compensation where expenses proven and admitted.
1 February 2023