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

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70 judgments
Citation
Judgment date
December 2023
Urgent enforcement of post-contract restraints dismissed for insufficient evidence and procedural non-compliance.
Restraint of trade – enforcement of post-termination restraints – requirement to prove protectable confidential information/customer connections; Evidence – need for particularity and corroboration of alleged solicitation; Territorial limits of restraints – conduct outside defined territory not automatically a breach; Procedural law – urgent application must comply with Court’s urgency rules and proper certificate of urgency; Franchisor/franchisee distinction – franchisee conduct not prima facie imputable to franchisor without evidence of collusion.
20 December 2023
Municipality liable for injuries from uncovered stormwater drain due to inadequate temporary barrier and lack of monitoring.
Municipal liability for defective public infrastructure; duty to safeguard after notice; adequacy and monitoring of temporary safety measures; negligence of public authority; contributory negligence of pedestrian.
5 December 2023
November 2023
Applicant failed to prove ownership of attacking dog; actio de pauperie claim dismissed and negligence not established.
Actio de pauperie – liability founded on ownership; possession insufficient; onus on plaintiff to prove ownership; evidential weight of SPCA/impoundment forms; development of common law requires proper pleading and fair notice; negligence claim where escape caused by third party not imputed to absent owner.
14 November 2023
Whether the defendant must pay plaintiff’s trial-day and attendance costs where disputed dates were, on the facts, set down for trial.
Costs — entitlement to trial-day and counsel fees — whether matter was set down for trial or stood down for settlement — attendance fees for appearances before Deputy Judge President — factual inquiry into court file and orders.
1 November 2023
October 2023
Accused entitled to sections B and C of the docket where prima facie relevance shown and no objective risk to justice proved.
Criminal procedure – disclosure of police docket – access to sections B and C – Shabalala/K ing principles; prima facie relevance; balancing fair‑trial right to adduce and challenge evidence against State’s claim of privilege and risk to proper ends of justice; Panayiotou two‑leg test applied.
20 October 2023
Section 163 permits a director or shareholder in a deadlock to obtain a court-ordered buy-out at fair value.
Companies law – Section 163 Companies Act – oppression/unfair prejudice remedy – available to director/shareholder in management/voting deadlock; court-ordered buy-out at fair value; open offer may cure prejudice only if demonstrably fair; section 162 delinquency not established on these facts; valuer appointment and powers; declaration of unauthorised transactions.
12 October 2023
A suspended sentence’s terms must be clear; ambiguity requires setting aside and substituting a precise sentencing order.
Sentencing — Suspended sentence — Formulation must be clear and precise; ambiguity as to whether part of fine is suspended invalidates sentence wording — Review under s304(4) Criminal Procedure Act appropriate to correct unclear sentence.
6 October 2023
Mandament van spolie granted restoring church possession; counter‑spoliation failed as repossession was not instanter.
Property/spoliation – mandament van spolie established where applicant peaceably possessed and was unlawfully dispossessed; counter‑spoliation defence requires repossession instanter and fails where repossession occurred days later; final interdict appropriate where prior court order creates clear right and reasonable apprehension of injury; judicial restraint against entanglement in internal religious governance; costs partly awarded (50%).
3 October 2023
The court reviewed the Master's appointment of an evidence leader for a liquidator's enquiry, emphasizing procedural rationality.
Company law—Section 381 enquiry—Appointment of evidence leader—Master's administrative actions—Judicial review and locus standi.
3 October 2023
September 2023
Court holds settlement order recorded consent to consolidation; purported cancellation unlawful and separate levies prohibited.
• Civil procedure – interpretation of settlement agreement made an order of court – Endumeni and Eke principles applied. • Property/land use – consent to consolidation versus municipal subdivision/rezoning approvals. • Enforcement of settlement orders – res judicata effect; cancellation held unlawful. • Non-joinder – municipal non-joinder not fatal where relief concerns contractual consent and levy treatment.
26 September 2023
Court appointed confidential child psychologist and empowered parenting coordinator to protect children’s interests amid acrimonious divorce.
Family law – Rule 43 – Appointment of child psychologist to address children’s emotional welfare; confidentiality of therapeutic findings; appointment of parenting coordinator/mediator with power to issue binding directives pendente lite; refusal to order compulsory psychological evaluation of a parent; costs and procedural propriety in urgent children’s applications.
26 September 2023
Pleadings read pragmatically supported a fraud/theft cause of action against second and third defendants; exceptions dismissed.
Civil procedure – exception to particulars of claim – test for exception: whether on every reasonable interpretation no cause of action may be made out – pleadings to be read pragmatically; delictual liability – fraud/theft – liability of non-signatory defendants alleged through collusion, knowledge and dissipation; proprietary remedies (rei vindicatio/actio ad exhibendum) inappropriate for money deposited with bank (ownership passes to bank).
26 September 2023
An exception to delictal claims for municipal negligent omissions fails where pleaded facts plausibly establish a legal duty and wrongfulness.
Municipal liability – delict – pure economic loss – wrongfulness distinct from negligence – "something more" required for administrative breaches; negligent misstatement and omissions; interplay between PAJA and Aquilian liability; exception for failure to disclose cause of action.
7 September 2023
An executor/attorney who pursues unmeritorious litigation may be ordered to pay costs de bonis propriis and reported to regulators.
Executor and attorney – fiduciary duties – litigating in both capacities – de bonis propriis costs – improper, negligent or unreasonable conduct by fiduciary or practitioner – duty to consider estate resources – notification to Legal Practice Council and Master of High Court.
5 September 2023
Separate loss‑causing events (two fires) preclude joinder under the Apportionment Act and rule 13; further amendment refused.
Apportionment of Damages Act s 2(1) – 'the same damage' requires one loss‑causing event; separate fires constitute separate damage – Rule 13 joinder – allows declaratory apportionment only, not monetary claims between wrongdoers – Exception practice – repeated futile amendments may justify refusal of further leave to amend.
5 September 2023
Exception upheld: particulars failed to plead a sustainable cause of action and omitted applicable foreign law, causing vagueness and prejudice.
International contract – suspensive condition not fulfilled – contract void ab initio; Distinction between contractual restitution and unjustified enrichment (condictio indebiti); Pleading requirements for foreign law and proper law of contract; Exception for lack of cause of action and vagueness/embarrassment; Leave to amend particulars of claim.
5 September 2023
August 2023
Buyer failed to prove seller knowingly concealed a latent defect; voetstoots clause upheld and claim dismissed.
Sale of goods – voetstoots clause – latent defects – seller’s liability excluded unless buyer proves seller knew of and fraudulently concealed defect; corporate knowledge – knowledge attributable only to directing mind and will, not mere clerical staff; invoices and internal processes – invoice to creditors clerk insufficient to notify or bind seller’s authorising/technical personnel; fraud distinguished from negligence; costs – difficult questions of law/fact justify higher tariff under Magistrates’ Court rule 33(8).
22 August 2023
Court convicted the accused of raping two minors, accepting a single complainant’s credible testimony and rejecting the accused’s improbable version.
Criminal law – rape – single witness (child) evidence – cautionary approach – assessment of inconsistencies and inherent probabilities – conviction on single credible witness plus supporting ‘mosaic’ evidence – no adverse inference where complainant psychotic and unable to testify.
18 August 2023
Sale of jointly owned land without a co-owner's written consent is void despite deeds registration; estoppel did not cure it.
• Alienation of Land Act s 2(1) – written signature/authority required for alienation of land; non-compliance renders transaction of no force or effect. • Alienation of Land Act s 28(2) – statutory cure requires full performance by all parties and valid transfer; registration alone insufficient where real agreement defective. • Transfer – abstract system: registration coupled with a valid real agreement (intention of transferor/transferee) required to pass ownership. • Estoppel by conduct – owner rarely estopped from vindicating property; must show representation by owner, reasonable reliance and prejudice; reliance on an imposter does not found estoppel against owner. • Remedy – setting aside of void sale and power of attorney; restitution and transfer back; costs allocation; s 28(1) monetary claims require evidentiary basis.
17 August 2023
A municipality’s belated rescission of a default judgment failed for lack of reasonable explanation and no prima facie defence.
Rescission of default judgment – common-law test (reasonable explanation and bona fide defence with prospects) ; Municipal procurement – emergency deviations under SCM policy; Validity of contracts and MFMA s116 requirements; Imputability of municipal officials’ knowledge; Admissibility of correspondence evidencing settlement and municipal conduct; Costs – punitive costs for dilatory or mala fide municipal conduct.
17 August 2023
NDPP failed to prove respondent entities held "realisable property" or received "affected gifts" from defendants; restraint discharged.
POCA — restraint orders — confirmation requires reasonable grounds for believing a confiscation order may be made; evidence must possibly support conviction and confiscation. "Realisable property" and "affected gift" — an affected gift requires that a defendant (directly or indirectly) made the gift; causal link to a charged person is essential. Statutory interpretation — term "defendant" cannot be extended to uncharged persons absent prosecution or clear statutory intention. Evidential sufficiency — transfers, valuations and assertions of payment-for-value must be supported by reliable evidence to justify restraint.
8 August 2023
Admitting and relying on hearsay in sentencing proceedings was a material misdirection, reducing an otherwise custodial sentence.
Criminal law — Sentencing — Admissibility of hearsay in aggravation — s3 Law of Evidence Amendment Act 45 of 1988 — pre-sentence reports and victim-impact evidence — impermissible reliance on hearsay vitiates sentencing exercise; Criminal law — Sentencing — Use of minimum-sentence 'yardstick' where minimums inapplicable and defence precluded from addressing such considerations — misdirection warranting appellate interference; Fraud — breach of trust by employee — seriousness and mitigation assessed.
8 August 2023
July 2023
Dog owner negligent for failing to control escaping dogs which foreseeably caused a passerby to retreat, trip and be injured.
• Delict – negligence – dog owner’s duty to control pets to prevent escape and endangering passersby – foreseeability and causation. • Factual disputes – assessment of credibility, reliability and probabilities in mutually destructive versions. • Costs – refusal of punitive (attorney-and-client) costs despite protracted cross-examination.
18 July 2023
June 2023
Credible single-witness identification, corroborated by ballistics and CCTV, supports convictions for gang-related murders and possession offences.
Criminal law – single-witness identification and corroboration; common purpose doctrine – participation and mens rea; POCA – gang membership and acts in furtherance of gang activity; admissibility and validity of search and seizure; circumstantial and ballistic evidence – inferential reasoning (R v Blom).
30 June 2023
A pending action disputing the same procurement transactions bars a concurrent review; review stayed against the First Respondent.
Administrative law; review of procurement decisions; collateral challenge to contract validity; lis alibi pendens (stay of review where same dispute pending); discretion to stay proceedings; delay and acquiescence in review applications.
15 June 2023
Interim interdict preserves mayoral executive pending review where MEC proceeded despite a prima facie IRFA intergovernmental dispute.
Local government — structures — MEC’s amendment of municipal executive system from mayoral to collective — interlocutory striking out of affidavits where co-respondents seek applicant’s relief without joinder — joinder of supporting respondent — interim interdict pending review where IRFA dispute-resolution not followed — separation of powers considerations in interim relief.
15 June 2023
Partial rescission of a consent order raises triable issues; it cannot be defeated by a special plea asserting the deed remains binding.
Family law; settlement agreement incorporated as court order – effect of novation by operation of law; rescission of parts of consent order under Rule 49(8); enforceability of court orders until set aside; procedural competence of special plea to decide triable issues (fraud/inducement).
13 June 2023
Applicant failed to prove an oral contract with respondent; agent contracted for a separate finance/support entity rather than respondent.
Contract — oral agreement — animus contrahendi — agent’s intention to contract for principal or for separate finance entity — proof on a balance of probabilities; payments made by subsidiary/finance unit (SBFS/RIDA) not proof of defendant liability.
13 June 2023
Court suspended pilot‑licence suspension pending review, exempting applicant from internal appeal as committee was non‑operational.
Civil aviation — suspension of pilot's licence — urgency — exemption from exhausting internal remedies under s 7(2)(c) PAJA where appeal committee non‑operational — requirement to consider all relevant factors in administrative decision‑making (including 'likelihood' in risk assessment) — procedural fairness — interim interdict test applied; suspension of implementation pending review.
6 June 2023
An applicant suing a carrier for damaged goods need not allege employees acted within the scope of their employment.
Contract of carriage – carrier as depositary/bailee for reward – duty to exercise reasonable care and liability for loss unless carrier proves absence of culpa. Pleadings – in actions for damaged goods under a contract of carriage, plaintiff need only allege contract, implied term to deliver undamaged, breach and particulars of damage. Scope of employment – not required to be pleaded where carrier liability arises by operation of law. Exception – conflation of contract and delict and failure to plead scope of employment are insufficient grounds where carriage law applies.
6 June 2023
May 2023
Leave to appeal refused where objective documentary evidence established the applicants' indebtedness to the respondent.
Civil procedure — leave to appeal — s17(1) Superior Courts Act — leave requires reasonable prospect of success or other compelling reason; Evidence — loan agreement, debit order, payments and account statements as conclusive objective proof of creditor-debtor relationship; Appeal — meritless challenge to identity of creditor defeated by uncontradicted documentary and conduct evidence.
30 May 2023
A disciplinary letter sent only to the plaintiff was defamatory; publication established and qualified privilege forfeited by malice, awarding R60,000 plus interest and costs.
Defamation — meaning and publication; republication and reasonable expectation — qualified privilege (duty/interest to inform) — forfeiture of privilege by malice or recklessness — damages for wounded feelings and reputational harm.
17 May 2023
Applicants declared vexatious for persistently pursuing unmeritorious litigation to revive set‑aside Public Protector remedial action.
Vexatious proceedings — application under section 2(1)(b) Vexatious Proceedings Act — requirements: persistency and absence of reasonable grounds. Abuse of process — repeated and unsuccessful attempts to revive set‑aside remedial action amounting to vexatious litigation. Practice — reliance on an earlier answering affidavit as evidential basis for related application is permissible to avoid duplication; leave to file supplementary affidavit granted. Rule 30/30A — challenge dismissed where relief is irrelevant, unsupported or beyond scope of Rule.
16 May 2023
Court interdicted consideration of invalid motions and ordered the Speaker to pay costs for ignoring rules and legal advice.
Local government — council procedure — validity of motions — municipal rules requiring motions signed, dated and submitted ten clear business days before meeting — urgency and final interdict to prevent unlawful council action — costs against Speaker for ignoring legal demand and opinion.
12 May 2023
Leave to appeal refused where rescission judgment was interlocutory and did not meet interests-of-justice appealability test.
Appealability of interlocutory orders – interests of justice test (Tswane City v Afriforum) – immediate and substantial effect; rescission of orders granting permanent residence; leave to appeal refused where no serious, immediate or irreparable harm.
9 May 2023
April 2023
Court awards R6,525,683 for future loss of earning capacity, preferring expert evidence of chronic pain and employment truncation.
• Personal injury – future loss of earning capacity – proof of truncation of working life and residual earning capacity – assessment by comparison of pre- and post-morbid earning capacity. • Expert evidence – joint minutes – weight to be accorded to agreed expert opinions; court may prefer one expert over another based on reasoning, investigation and consistency with facts. • Application of Kerridge approach – increased contingency deduction where post-accident earning prospects are uncertain. • Orthopaedic and psychological sequelae – chronic pain, Persistent Depressive Disorder and somatic symptom disorder as factors reducing employability. • Costs – award of taxed party-and-party costs and setting aside of contingency fee agreement.
25 April 2023
The defendant negligently performed revisional antireflux surgery without necessary investigations or assistance, causing severe injury and damages.
Medical negligence – reoperative antireflux (redo Nissen) surgery – failure to trial conservative therapy and obtain up-to-date preoperative investigations – undertaking complex revisional laparoscopic surgery without specialist assistance – causation of massive intra‑operative haemorrhage and long‑term neurological sequelae; Expert evidence – compliance with Uniform Rule 36(9).
25 April 2023
Assessment of minor’s loss of earning capacity after severe brain injury; court prefers conservative actuarial inputs and applies 25%/35% contingencies.
Road Accident Fund – loss of earning capacity of a brain‑injured minor – actuarial computation of pre‑ and post‑morbid earnings – choice of earnings survey (Deloitte vs STATSSA) – weight of expert evidence (educational and industrial psychologists) – contingency discounts (25% pre‑morbid; 35% post‑morbid) – intervention and schooling considerations.
16 April 2023
Municipal sale of tender documents limited to printing costs and failure to post online not unlawful; rule nisi discharged.
Procurement law – municipal tender procedures – CIDB Standard permits charging tender‑document fees limited to actual printing costs and encourages online availability; failure to post online not per se unlawful; PFMA/Treasury instruments and National Treasury Guide generally do not apply to municipalities; administrative action under PAJA must still be lawful.
6 April 2023
Prospective examinees lack standing to set aside an ex parte s417/418 enquiry order; challenges are limited to subpoenas or review.
Companies Act ss417–418 — s417/s418 enquiry — ex parte order authorising enquiry — locus standi of prospective examinee — limited grounds to oppose (jurisdiction, hardship/oppression, exceptional circumstances) — subpoenas duces tecum — procedural remedies: intervention under Rule 6(4)(b) vs reconsideration under Rule 6(12)(c) — review as remedy to challenge commissioner’s ruling — costs.
4 April 2023
Causation from the collision established; unpleaded claim of intervening medical negligence rejected; defendant liable for loss of support and funeral expenses.
Delict – causation – application of "but for" test – skull base fracture from motor collision established as cause of death. Novus actus interveniens – substandard medical treatment – requirement to plead special plea; unpleaded defence cannot be raised at trial. Quantum – proof of deceased’s earnings and actuarial calculation of loss of support; no contingencies applied. Costs – successful plaintiffs awarded costs including specified expert and counsel fees and interest.
4 April 2023
Warrantless arrest without reasonable suspicion is unlawful; police liable for initial detention but not for court-ordered subsequent detention.
Criminal procedure – arrest without warrant – section 40(1)(b) – reasonable suspicion must be based on solid grounds, not mere conjecture. Unlawful arrest renders initial detention unlawful. Separation of powers – police duty to bring arrested person to court; charging and bail decisions rest with prosecutor and magistrate; police not liable for subsequent court-ordered detention absent wrongful conduct. Damages for deprivation of liberty: award for two days’ unlawful detention.
4 April 2023
March 2023
Urgent relief granted: 18 October shareholders’ meeting invalid; purported director removals void ab initio; municipality’s intervention refused.
Companies Act — shareholders’ meeting — authority to convene and proper notice — meeting invalid where convening lacked authority and notice not given to all shareholders; corporate takeover — purported removal/election of directors void ab initio; urgency — abridgment of rules justified where imminent prejudice and inability to obtain adequate redress in due course; intervention — municipality lacks direct and substantial interest to intervene in private company internal dispute.
31 March 2023
Pleadings that allege ‘unlawful’ (negligent) prosecution cannot substitute for actio iniuriarum; absolution granted for failure to prima facie prove malicious prosecution.
Criminal procedure and delict – unlawful/negligent prosecution versus malicious prosecution – limits on a delictual claim by accused for ordinary negligence by prosecutors/police; absolution from the instance where no prima facie case for malicious prosecution is shown; pleadings must properly define whether reliance is on malice (actio iniuriarum) or unlawful/negligent prosecution.
28 March 2023
An urgent ex parte application to halt the transfer of estate property failed for lack of true urgency and proper notice.
Civil procedure – urgent applications – ex parte relief – requirements for urgency – proper notice – estate administration – sale of estate assets – interim interdict – self-created urgency – respect for court procedures and respondents’ rights.
22 March 2023
Applicant entitled to interdict for passing off: FIRELOGIK deceptively similar to and likely to be confused with FIRE LOGIC.
Passing off – requirement of distinctiveness/reputation; deceptive similarity of trade names (visual and phonetic) – likelihood of confusion; interdictory relief where likelihood of deception and likely loss; descriptive vs fancy names; interlocutory strike-out – unsubstantiated hearsay and costs.
17 March 2023
Exception partially upheld: cancellation claim stands; rei vindicatio defective; actio ad exhibendum need not plead mala fides.
Civil procedure — exception to particulars of claim — meaning and ambit of averments on exception; factual disputes not resolved on exception. Contract law — domicilium clause and service — nominated domicilium not necessarily peremptory; service on attorneys may suffice where notice comes to addressee's attention. Property law — rei vindicatio — claimant must allege defendant was in possession when action instituted. Delict/condictio — actio ad exhibendum — claimant need not plead mala fides as separate element; must show disposer acted with dolus or culpa and knew claimant's ownership.
16 March 2023
High Court had concurrent jurisdiction to hear constitutional-rights based interdiction arising from strike conduct; jurisdiction assessed by pleadings.
Labour law; jurisdiction — s 157 LRA — concurrent jurisdiction of High Court and Labour Court where alleged or threatened infringement of constitutional rights arising from employment; jurisdiction determined by pleadings (Gcaba/Baloyi); s 68 LRA interdicts reserved to Labour Court.
15 March 2023
"Our children" in a clear joint will includes children born out of wedlock unless the will’s context excludes them.
Wills – interpretation – joint will – "our children" includes children born out of wedlock absent contextual indication to exclude them (s 2D Wills Act); extrinsic evidence inadmissible to vary clear testamentary language; latent ambiguity and admissibility of background facts; relief for unsuccessful postponement where undertakings and court rules breached.
14 March 2023
Respondent must prove lawfulness of admitted warrantless arrest; failure to do so renders detention unlawful and damages payable.
Warrantless arrest – onus on arresting party to prove jurisdictional facts; Resolution of mutually destructive versions – application of SFW technique; Credibility findings and probabilities; Adverse inference for failure to call available witness (police van driver); Damages for unlawful arrest impairing dignity.
14 March 2023