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

70 judgments
  • Filters
  • Judges
  • Case actions
  • Topics
  • Alphabet
Sort by:
70 judgments
Citation
Judgment date
March 2023
Appellate court upheld conviction on reliable identification and possession evidence but reduced an excessive 15-year sentence to seven years.
Criminal law – identification evidence – greatest care required where conviction depends on identification – corroboration by circumstantial evidence and possession of stolen property.* Criminal law – single witness – evidence requiring caution but admissible when corroborated.* Criminal procedure – appellate review – deference to trial court factual findings unless plainly wrong.* Sentencing – appeal against sentence – interference only where material misdirection or disproportionate/shocking term – substitution of sentence where necessary.
14 March 2023
Circumstantial evidence and an admission upheld a murder conviction despite identification misdirection; sentence reduced for excessiveness.
Criminal law – circumstantial evidence – conviction on circumstantial proof and admission; Identification evidence – single-witness identification and requirement of caution and assessment of reliability; Credibility – assessment of potentially biased witness (ex-wife) and application of Dhlumayo principles; Sentencing – interference where trial court misdirects by over-emphasising aggravation, failing to account for pre-trial custody, intoxication, and cumulative effect; Substitution and antedating of sentence.
14 March 2023
Leave to appeal refused: account-closure dispute is contractual, not a reviewable administrative action; Forum not a tribunal.
Banking law — termination of banking relationship — whether decision by private bank to close accounts is reviewable or a contractual matter; application of Jockey Club cases and Bredenkamp; role of Banks Conduct Standard (reasons and notice); requirements for leave to appeal under s 17 of the Superior Courts Act.
14 March 2023
Defendant failed to establish a bona fide defence to summary judgment after pleadings admitted a latent defect and inadequately pleaded warranty defence.
Civil procedure – Summary judgment – amended rule 14(3)(b) – defendant must disclose fully the nature and grounds of a bona fide defence and material facts relied upon. Sale of goods – latent defect – seed build-up in dispensing shoot of planter; seller's residual obligation not to sell defective goods. Pleading – requirements for pleading a warranty defence and particularity where modification of goods is alleged.
14 March 2023
State failed to prove rape beyond reasonable doubt due to unreliable child evidence and neutral medical and corroborative defence evidence.
Criminal law – sexual offences – assessment of young child complainant’s evidence – material inconsistencies and suggestibility; Medical evidence – neutral/inconclusive where injuries have alternative causes; Evidence assessment – not to compartmentalise state and defence cases; Standard of proof – conviction only where guilt proven beyond reasonable doubt; Van der Meyden principle applied to determine reasonable possibility of innocence.
13 March 2023
Accused’s late remorse and personal circumstances insufficient to justify departure from minimum life sentences for two rapes of a blind elderly victim.
Criminal law – sentencing – Minimum Sentences Act s51(1) – substantial and compelling circumstances; section 112(2) plea and weight of guilty plea/remorse; vulnerable victim (physically disabled/elderly) and multiple rapes; Zinn triad sentencing analysis.
10 March 2023
A magistrate’s condonation order is challengeable on review only for conduct‑based gross irregularity, not as administrative action under PAJA.
Administrative law – PAJA – judicial functions excluded: decisions of judicial officers are not "administrative action". Superior Courts Act s22 – review of Magistrates' Court proceedings limited to absence of jurisdiction, bias, gross irregularity, and evidentiary errors. Gross irregularity – must relate to the method/conduct preventing a fair trial, not mere erroneous outcome or error of law on the merits. Procedural finality/time‑bar – challenges to the correctness of a dismissal for non‑compliance are appeal issues, not reviewable as administrative irregularity.
2 March 2023
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
January 2023
Failure to comply with a Banks Act repayment directive is a statutory act of insolvency permitting final sequestration.
Banks Act s83(3)(b) – failure to comply with repayment directive deemed act of insolvency; sequestration proceedings not subject to Prescription Act; Deputy Registrar/Prudential Authority competent to institute proceedings; repayment directive validity and repayment administrator’s investigatory role; final sequestration ordered.
31 January 2023
Interim interdict granted to suspend a tender award where the Department’s reasons were inadequate and review likely.
• Administrative law – public procurement – adequacy of reasons for tender decisions – PAJA and transparency obligations; • Interim interdict – prima facie right, irreparable harm and balance of convenience in stay-of-implementation pending review; • Urgency and condonation for non-compliance with court rules; • Locus and standing of disappointed tenderers; • Constitutional duty of legality and openness in procurement processes.
24 January 2023
A regulation barring recording a child’s foreign or undocumented father is unconstitutional as discriminatory and contrary to children’s rights.
Constitutional law – justiciability – court may decide constitutional challenge despite late concession where issue was actively opposed and has public importance. Administrative / statutory interpretation – Regulation 12(2)(c) of the Births and Deaths Registration Regulations. Children’s rights – right to dignity and best interests – discrimination where father's immigration status conditions registration of paternity. Conflict between subordinate regulation and section 11 of Births and Deaths Registration Act and Children’s Act. Costs – adverse punitive costs where state conduct unreasonably delayed and opposed relief.
10 January 2023