High Court of South Africa Eastern Cape, Port Elizabeth - 2024

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86 judgments
Citation
Judgment date
December 2024
Whether substantial and compelling circumstances justify deviation from prescribed minimum sentences for violent robberies and a murder.
Sentencing — Criminal Law Amendment Act prescribed minimum sentences — substantial and compelling circumstances — application of S v Malgas and S v Vilakazi — Zinn triad — robbery with aggravating circumstances and murder during robbery (life sentence) — unlawful possession of firearm and ammunition — s103(1) Firearms Control Act (unfitness to possess).
19 December 2024
Provisional sentence refused because the acknowledgement of debt was vague and not a liquid document.
Provisional sentence – liquid document – acknowledgment of debt must disclose an unconditional, ascertainable indebtedness; Contract interpretation – offer and counter-offer determine acceptance and jurisdiction; Vagueness/uncertainty – instalment mechanisms and set-off provisions may render an acknowledgement non-liquid; National Credit Act – applicability determined by asset and turnover thresholds.
10 December 2024
A Road Accident Fund claim becomes legally valid if the Fund fails to object within s24(5)’s 60‑day period.
• Road Accident Fund Act s 24(5) – timeous objection: failure to object within 60 days renders claim valid in law. • Administrative instruments – Board Notice 271 of 2022 and prescribed RAF1 – declared unlawful; Fund cannot rely on them. • Procedural consequence – late objection raised in amended plea is ineffective to defeat deemed validity.
10 December 2024
High Court refused interlocutory review: charge particulars and state disclosure were sufficient; issues are matters for trial.
Criminal procedure – review of unterminated proceedings – exceptional interference only for gross irregularity or grave injustice not remedyable on appeal. Criminal Procedure Act ss 84, 87 – essentials of a charge and requests for further particulars – sufficiency to inform accused and avoid trial by ambush. Common purpose and jurisdiction – factual issues for evidence, not necessarily for further pleading. Disclosure – provision of docket and witness statements may render further pleading unnecessary. Superior Courts Act s 22 grounds for review (absence of jurisdiction, bias, gross irregularity, evidentiary errors).
5 December 2024
Applicants failed to prove urgency or protectable customer connections; restraint unenforceable and application dismissed.
Employment law – Restraint of trade and confidentiality – urgency under rule 6(12) – onus to establish protectable customer connections or risk of misuse of confidential information – enforcement requires detailed factual foundation about personal customer relationships, frequency/duration of contacts and demonstrable risk of prejudice.
3 December 2024
November 2024
Defendant’s wilful non‑compliance with an order to provide trial particulars warranted coercive relief and adverse costs.
Rule 21(4) – enforcement of request for trial particulars; contumacious non‑compliance and sanctions; court discretion to strike out defence or craft coercive orders; interplay with Rule 30A; double‑barrelled claims and prescription issues (Rademeyer).
29 November 2024
Applicants need not give reasons for removing directors; board must convene meeting after receiving drafted resolutions.
Companies Act s61(3) – shareholder demand to convene meetings; s62 and s65 notice and resolution requirements; s71 removal of directors – distinction between shareholder-initiated removals and board-initiated removals; directors not entitled to pre-meeting reasons for shareholder-initiated removal; interpretation of memorandum of incorporation; urgency under Rule 6(12) and section 61(12).
28 November 2024
Court ruled unlawful arrest and detention and awarded damages for lack of reasonable suspicion and procedural integrity.
Criminal Law—Arrest without warrant—Reasonable suspicion assessed—Lawfulness of arrest and further detention—Possible malicious prosecution.
28 November 2024
Contempt application dismissed: non-compliance not shown to be wilful and mala fide; payment plan ordered for assumed arrears.
Family law – enforcement of maintenance order – civil contempt – requirements: order, service, non-compliance, wilfulness and mala fides – evidential onus shifts to respondent once order, service and non-compliance proved – genuine efforts to purge arrears can defeat contempt – structured payment plan as alternative remedy.
26 November 2024
Insurer’s repudiation complied with PPRs; no duty to search prior applications; applicant’s challenge dismissed with costs.
Insurance – Long-term insurance – Policyholder Protection Rules (PPRs) – Rule 17.6.3(a) – Insurer must inform claimant in plain language of reasons for repudiation in sufficient detail. Insurance – Non-disclosure/misrepresentation – insurer entitled to avoid policy where applicant’s telephonic underwriting answers omitted material medical history. Insurance – No general duty on insurer to search prior application records or 'fossick' for earlier disclosures, particularly where different distribution channels/systems were used. Civil procedure – condonation – late filing of answering affidavit condoned where adequate explanation provided.
19 November 2024
Mother's relocation with child upheld pending further inquiry, as court prioritizes child's best interests interim.
Family law – Child custody – relocation of minor child by primary caregiver – best interests of child – interim arrangements pending Family Advocate’s report.
19 November 2024
A conditional Rule 34 tender tied to a sale and not complying with rule 34(5) cannot justify revising a costs order.
Costs — Rule 34 offers to settle — applicability where plaintiff is defendant in reconvention — peremptory compliance with Rule 34(5) — conditional tenders (payment upon sale) non-compliant — discretion to reconsider costs under Rule 34(12).
14 November 2024
October 2024
Defendant liable where its insured entered an intersection against a red light; plaintiff not contributorily negligent.
Road Accident Fund claim — liability under s17(1) RAF Act — whether insured driver entered intersection against red light and failed to keep proper lookout — assessment of conflicting witness accounts and eyewitness corroboration — contributory negligence (Apportionment of Damages).
31 October 2024
A s424(1) claim must plead sufficient facts of participation, knowledge and causation; vague conclusions are excipiable.
Companies Act s424(1) – personal liability for reckless or fraudulent carrying on of company business – pleading standards – plead material facts of participation, knowledge and causation; pleadings stating conclusions (e.g. "recklessness", "misrepresentation") without supporting particulars are vague and excipiable; deficiencies should be cured by amendment, not by evidence or discovery.
22 October 2024
Rescission granted where third‑party joinder was procedurally defective and judgment was erroneously granted in absence.
Civil procedure – rescission (rule 42(1)(a)) – erroneous grant where party not procedurally entitled to judgment; Third‑party joinder (rule 13) – consortium is not a juristic person; individual members must be cited; Scope of relief under rule 13 – generally declaratory/apportionment, monetary/joint and several orders inappropriate in absence of legal basis; Default and wilful default – reasonable explanation can justify rescission; Costs – award of scale C for rescission applicant and wasted costs on scale B.
17 October 2024
A motion alleging environmental nuisance from manganese was referred to trial due to material, foreseeable disputes of fact.
Environmental law / nuisance – alleged pollution and dust from stockpiled manganese; potential health and ecological harm. Civil procedure – referral to trial under Uniform Rule 6(5)(e) and 6(5)(g) where material disputes of fact exist. Foreseeability test – whether disputes of fact were reasonably foreseeable when instituting motion proceedings. Costs – applicants ordered to pay specified respondents’ costs on scale C; experts’ qualifying fees reserved for trial.
15 October 2024
Court found First Respondent complied with disclosure order, discharged that paragraph and awarded costs against respondents.
Civil procedure – urgent application – interim rule nisi – disclosure of bank accounts and deposits – compliance with interim order. Civil procedure – condonation of late filing of answering affidavit – delay explained and condoned. Contempt – allegations not properly pleaded in answering/ replying affidavit – application for contempt must be brought on notice. Relief not sought in notice of motion – further and/or alternative relief must be pleaded and supported on the papers. Costs – respondents ordered to pay applicant’s costs (not punitive).
8 October 2024
Particulars seeking access to company‑owned property were vague, failed to disclose a cause of action, and exceptions were upheld.
Pleadings – exception under Rule 23(1) – particulars of claim vague and embarrassing – failure to disclose cause of action; Agreement partly oral/partly written – lack of particularity and inconsistent annexures; Alienation of Land Act/formalities for interests in land and executory donations; Director’s authority to bind company insufficiently pleaded; Relief vague and uncertain (unspecified beneficiaries, indeterminate periods).
8 October 2024
Judgment awards R5,243,568 (after interim payment) for loss of earnings following permanent leg injuries; actuarial Scenario 2 accepted.
• Damages – loss of earning capacity – quantification by actuarial calculation based on joint expert minutes – contingency deductions applied. • Medical evidence – joint orthopaedic, occupational therapy and industrial psychology minutes accepted on permanent impairment and restricted capacity. • Actuarial scenarios – court preference for scenario assuming nil injured future earnings where supported by evidence. • Costs – defendant liable for taxed or agreed costs including specified expert fees and two counsel where employed.
8 October 2024
Failure to plead essential contractual "milestones" rendered the particulars vague and embarrassing, requiring amendment within 15 days.
Exception – vagueness and embarrassment – high threshold; must show vagueness and serious prejudice – pleadings read holistically; Rule 18(6) – contracts must state if written or oral and annex written portion; Rule 23 v Rule 30A – distinction between vagueness striking at cause of action and mere lack of particularity; Contractual milestones – failure to plead essential terms may render pleading excipiable.
1 October 2024
September 2024
Warrantless search and seizure of a correctional official’s phones without consent or National Commissioner authorisation was unlawful; spoliation granted.
Correctional Services Act s101(2) — peremptory prohibition on searching a correctional official or seizing property without consent or National Commissioner authorisation; mandament van spolie — available against state organs; public power and doctrine of legality; urgency and condonation; unlawful seizure null and void.
19 September 2024
Court postponed provisional liquidation, ordered comprehensive opposing affidavit and de bonis propriis costs against withdrawing attorney.
Company law – provisional liquidation – urgency – court found no exceptional urgency beyond alleged criminal conduct; Representation – a director who is not a legal practitioner generally may not represent a company in court except in very exceptional circumstances; Civil procedure – attorney’s withdrawal not in accordance with Rules of Court – costs de bonis propriis ordered; Procedural fairness – respondent ordered to file comprehensive opposing affidavit with specified timetable.
18 September 2024
High Court dismisses urgent parenting/contact application because extant children’s court orders and lis alibi pendens bar relief.
Family law – Urgent High Court application for primary care/contact – Effect and binding force of existing children’s court orders – Doctrine of lis alibi pendens – Necessity of family advocate’s report to determine best interests of the child – Forum shopping and obedience to court orders (s 165(5) Constitution).
17 September 2024
Court-ordered business rescue commences on the s 131 court order; ‘creditor’ may include contractual delivery rights, limiting intervention to affected persons.
Companies Act — s 131 business rescue: commencement occurs on court order placing company under supervision; application initiates process but does not itself commence proceedings; business rescue practitioner and supervisory regime operate post-order. Participation — only ‘affected persons’ (creditors, shareholders, employees) at commencement may participate; former creditors excluded. ‘Creditor’ — includes non-monetary and future/contingent contractual rights (e.g. packrights) for participation purposes. Intervention — Uniform Rule 12 and general intervention principles do not displace Act’s tailored participation regime.
17 September 2024
Court grants interim maintenance and reduced legal-costs contribution; condonation granted and voluminous pleadings criticised.
Family law – Rule 43 interlocutory relief pending divorce – condonation for late sworn reply; abuse of process and prolix pleadings; interim maintenance for minor children; payment of school fees and medical aid; refusal to order replacement vehicle; contribution to legal costs reduced as excessive; costs each party own.
3 September 2024
A monetary transfer used to buy registered property vested inter vivos, not a donatio mortis causa, so repayment claim dismissed.
Donatio mortis causa v donatio inter vivos – vesting test to determine pactum successorium; presumption in favour of inter vivos donation; testamentary formalities required for donatio mortis causa; revocation and enforceability where donation vested inter vivos.
3 September 2024
August 2024
Leave to appeal was granted on whether a damages claim against attorneys was prescribed, turning on the timing of knowledge.
Prescription – commencement of prescription – professional negligence – knowledge of facts necessary for claim – interpretation of communications between attorney and client – leave to appeal – reasonable possibility another court may differ.
29 August 2024
SARS lawfully recovered pension funds via a s 179 TAA third‑party notice; PFA s 37A does not bar such recovery.
Tax law – Tax Administration Act s 179 – third‑party appointment/IT88 – pay‑now‑argue‑later enforcement of tax debts Pension funds – Pension Funds Act s 37A – interaction with later TAA provisions; implied override by later statute Constitutional law – right of access to social security (s 27) – reasonable and justifiable limitation by tax recovery measures Civil procedure – condonation for late filing – test applied and granted
27 August 2024
An interim arbitration measure does not attract statutory post-award interest where contract expressly excludes interest on adjudication amounts.
Arbitration and interest – Interim measures do not constitute awards under s29 Arbitration Act; Interest Act inapplicable absent judgment/award; Contractual no-interest clause binds adjudication amounts; Civil procedure – amendment incompetent where court order has defined issues; lis pendens and arbitration process limit court intervention.
20 August 2024
Condonation granted for late statutory notice: good cause and minimal prejudice, despite uncertain prospects.
Institution of Legal Proceedings Against Certain Organs of State Act 40/2002 — s3(2)(a), s3(4): condonation for late statutory notice; requirements of prescription, good cause and unreasonable prejudice; assessment of prospects of success; weight of applicant’s bona fides and explanation; litigation costs by organ of state insufficient to show unreasonable prejudice.
20 August 2024
An estate representative may enforce a valid written deed of sale against a purchaser; payment must be made to the estate under estate administration rules.
• Property law – Alienation of Land Act s 2(1) – written deed of sale for land signed by parties is required and enforceable. • Succession/estate administration – letters of authority under Administration of Estates Act empower the estate representative to claim monies due to the estate and require payment into estate accounts. • Contract interpretation – peremptory written terms (entire agreement clause) bind parties; extrinsic, unattested statements cannot vary the deed. • Civil procedure – where no real dispute of fact exists, monetary claims under admitted written contracts may be pursued by motion.
20 August 2024
A plaintiff is entitled to have legal representation present during Rule 36 psychological and psychiatric assessments.
Rule 36(1) – medical examinations for damages – entitlement to legal representation at forensic psychological and psychiatric assessments; application of Goldberg; admissibility and protection of audio‑visual recordings; constitutional rights to bodily and psychological integrity; costs order including two counsel and expert costs.
13 August 2024
July 2024
Bail refused due to lack of exceptional circumstances under section 60(11)(a) CPA for a serious crimes defendant.
Criminal Procedure – Bail application in serious offenses – Exceptional circumstances under section 60(11)(a) of CPA – Flight risk and obstruction of justice concerns.
30 July 2024
Execution of a primary residence refused under Rule 46A because sale would infringe the debtor's section 26(1) housing right.
Rule 46A – execution against primary residence – protection of section 26(1) right to adequate housing; factors to be weighed include primary residence status, circumstances of incurring debt, payment history, outstanding mortgage, and proportionality of prejudice; subsequent payments and debtor’s employment relevant to resisting execution.
9 July 2024
June 2024
Life sentences imposed for two rapes by a parental figure; mitigating factors insufficient to establish substantial and compelling circumstances.
Criminal law – Minimum sentencing – Section 51(1) Criminal Law (Sexual Offences and Related Matters) Amendment Act – Rape of child and repeat offences attract mandatory life unless substantial and compelling circumstances established; factors: abuse of trust, victim impact, remorse, personal circumstances, proportionality.
28 June 2024
Regional Council entitled to spoliation relief after coerced dispossession; Rule Nisi confirmed and costs awarded.
Property/Spoliation — mandament van spolie — requirement of peaceful and undisturbed possession; voluntary surrender versus coerced dispossession. Locus standi — Regional Council’s authority to act for a debilitated local church under the UCCSA constitution. Procedure — condonation/filing of affidavits through registrar without leave; postponement as discretionary indulgence; refusal where tactical delay suspected. Relief — confirmation of Rule Nisi and costs on scale A.
25 June 2024
Conviction for assault with intent to do grievous bodily harm set aside; substituted with common assault and an appropriate suspended fine.
Criminal law – Assault – Distinction between common assault and assault with intent to do grievous bodily harm; requirement to prove or admit intent to do grievous bodily harm; competent verdict under s 266(a) Criminal Procedure Act; review and substitution of conviction and sentence; sentencing principles and suspension of sentence.
25 June 2024
Court set aside immigration decisions and remitted them for reconsideration; declined substitution absent exceptional circumstances.
Administrative law — PAJA s 8(1)(c)(ii) — substitution versus remittal of administrative action — ‘exceptional circumstances’, ‘foregone conclusion’, and ‘in as good a position’ tests — separation of powers and deference to administrators — immigration decisions and internal review — remittal with directions and timeframes — costs awarded to successful applicant.
11 June 2024
May 2024
Court awards damages for plaintiff's blindness due to negligence in handling original claims for compensation.
Damages - determination of general damages for blindness - negligent handling of claims by law firms - award balanced against current standards and precedents.
23 May 2024
Claims against an organ of state dismissed: earlier claims prescribed and no statutory ILPACOSA notice or condonation provided.
Prescription – s 11(d) Prescription Act – delictual claims arising 5 September 2016 prescribed where summons served after three years; prescription not subject to judicial condonation. Institution of Legal Proceedings Against Certain Organs of State Act – s 3(1)–(2) notice requirement is peremptory/jurisdictional; failure to serve notice and failure to apply for condonation under s 3(4) renders proceedings unenforceable. Pleadings – replication required to meet special plea; absent replication evidence of compliance is irrelevant and inadmissible.
16 May 2024
Divorce-derived personal right to transfer precedes creditor's claim; registration required before property becomes executable.
Property law; transfer of immovable property requires registration (s16 Deeds Registries Act); deed of settlement in divorce creates a personal right to compel transfer; section 45bis endorsement; creditor's subsequent judgment cannot defeat pre-existing personal right to transfer.
14 May 2024
Review of magistrate’s protection order dismissed for lack of gross irregularity; appeal was the proper remedy.
Domestic Violence Act — protection order granted in absentia — wilful absence — review v appeal — requirement to establish gross irregularity and prejudice on review — judicial bias allegation rejected — costs: ordinary scale.
14 May 2024
April 2024
The plaintiff, struck by an unidentified vehicle, proved negligence and causation; the defendant held liable for 100% of proven damages.
Road Accident Fund liability – pedestrian struck by unidentified vehicle – proof of negligence and causation at merits stage – admissibility and weight of medico‑legal evidence – amendments to particulars – failure by defendant to advance a version or prove contributory negligence – costs order including expert and inspection costs.
30 April 2024
The applicant’s arrest and detention were lawful based on reasonable suspicion from credible eyewitness identification.
Arrest without warrant — reasonable suspicion — eyewitness identification and pointing out; Exercise of discretion to arrest — objective rationality; Lawful detention pre-appearance (s39(3) CPA); Post-appearance remand — prosecutor’s duty to place fair and honest facts before court; No liability for unlawful arrest or detention where suspicion and remand are objectively justified; Costs including wasted costs.
30 April 2024
Commercial inconvenience did not establish urgency; eviction application struck from the roll with costs.
Urgency — Rule 6(12) — applicant must set out explicit circumstances showing inability to obtain substantial redress in due course; commercial prejudice may justify urgency but must be convincingly pleaded; contractual clause allowing delayed occupation (clause 3.3) negates claim of irreparable prejudice; abridgement of time must respect prejudice to respondent and other litigants.
24 April 2024
Court orders additional admiralty security for a crystallised bunker claim and upholds urgent procedure and jurisdiction.
Admiralty — increased security under s 5(2)(d) — jurisdiction where arrest and security previously granted — urgent procedure under Practice Rule 12 — prima facie claim and genuine/ reasonable need for security — security for foreign arbitration claims — quantum for top-up security.
23 April 2024
Vehicle used to transport stolen goods declared forfeited under POCA; owner failed to establish innocent-owner defence.
POCA Chapter 6 – civil forfeiture of instrumentalities – not conviction-based; focus on property’s functional role. Instrumentality – must play a reasonably direct, substantial and meaningful role in the commission of the offence (Prophet factors). Innocent/ignorant owner defence – owner must show lack of knowledge or reasonable suspicion; state bears balance of probabilities. Proportionality enquiry (Mohunram/Prophet) – weigh effects on owner against societal purposes of forfeiture.
23 April 2024
Failure to set out clear grounds and explain default renders leave-to-appeal application fatally defective; upliftment premature without Rule 27(1) compliance.
Civil procedure – leave to appeal – Rule 49(1) peremptory requirement that grounds be set out clearly and succinctly – non-compliance renders application fatally defective/nullity. Civil procedure – default and upliftment of bar – requirement to give full and reasonable explanation covering entire delay; reckless or intentional disregard of rules may defeat upliftment. Civil procedure – Rule 27(1) – agreement to uplift the bar must be sought before application; failure renders upliftment premature. Condonation – discretion to condone late filing despite lack of good cause; indulgence may attract costs against the applicant.
17 April 2024
Arrest after voluntary interview was lawful: reasonable suspicion existed, discretion properly exercised, and detention justified.
Criminal procedure – arrest without warrant – s 40(1)(b) CPA – reasonable suspicion must be objective, based on specific and articulable facts. Arresting discretion – must be bona fide, rational and non-arbitrary; seriousness of scheduled offences relevant. Detention pending first appearance – release limited where scheduled/serious offences suspected. Appeal – reluctance to disturb trial court factual findings absent misdirection; appellate inference-drawing where appropriate.
16 April 2024
Applicants who withdrew their post-set-down applications were ordered to pay wasted costs; punitive costs were refused.
Civil procedure – withdrawal after set-down (Rule 41(1)) – withdrawing litigant ordinarily liable for costs – exceptional circumstances required to deny costs – Biowatch principle inapplicable where constitutional challenge not pleaded – attorney-and-client costs reserved for clearly vexatious or reprehensible conduct.
11 April 2024