High Court of South Africa Eastern Cape, Port Elizabeth

305 judgments
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305 judgments
Citation
Judgment date
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
Leave to appeal against validation of a customary marriage under s3(1)(b) lacked prospects; appeal dismissed with costs.
Customary marriage — s 3(1)(b) requirements (consent, lobola negotiation/acceptance, celebration) — emissaries and utsiki — living customary law; Leave to appeal — Superior Courts Act s 17(1) heightened threshold; Condonation and costs — costs follow results.
9 April 2024
Whether the appellant lawfully arrested and detained the respondents under s40(1)(b); court found unlawful, awarded R50,000 each.
Criminal procedure – Arrest without warrant – s 40(1)(b) CPA – reasonable suspicion must rest on solid grounds; reliance on undisclosed informant insufficient where particulars not verified; Detention – s 50 CPA – continued detention unlawful once investigating officer finds no link; Quantum – solatium for unlawful arrest/detention assessed by duration, circumstances, conduct of police and cell conditions; costs of appeal awarded to successful respondents.
9 April 2024
An urgent application established that the Fund unlawfully refused to accept or acknowledge claim lodgements, risking prescription.
Administrative law – statutory body’s power to receive claims – s 24(1)(b) RAF Act – requirement to accept delivery and acknowledge receipt; no power to refuse acceptance. Civil procedure – urgency – Rule 6(12) – risk of prescription and absence of substantial redress. Road Accident Fund – RAF1 form and Board Notice 271 of 2022 – substantial compliance principle; Board Notice and 2022 RAF1 declared unlawful by Full Bench.
9 April 2024
A municipal-entity board unlawfully appointed an unqualified CEO; the appointment was reviewed and set aside.
• Administrative law – PAJA review – appointment of municipal-entity CEO – unlawfulness where appointee lacks prescribed competencies; • Local government – Systems Act – board’s exclusive power to appoint municipal-entity CEO (s 93J) and limits on application of senior-manager appointment regulations; • Municipal Finance Management Act – competency regulations require accounting officers to meet minimum financial and supply-chain unit standards; • Interpretation – scope of appointment regulations vs competency regulations; • Remedies – review and setting aside of appointment where decision materially influenced by error of law, irrational and procedurally defective.
9 April 2024
Review dismissed: condonation refused and matter barred by res judicata; no declaration of headmanship granted.
• Administrative law – condonation for late review – full explanation for delay required; attorney negligence insufficient without adequate personal steps by litigant. • Res judicata/issue estoppel – prior final judgment between same parties on same subject matter bars relitigation. • Traditional leadership – review of recognition and incumbency of headmanship; requirement of identification by legitimate royal family. • Remedies – declaratory relief cannot be granted absent consequential relief setting aside existing recognition.
9 April 2024
March 2024
The court found that the parties' marriage was valid under customary law, not affected by civil marriage intentions.
Family law – Customary marriage – Validity of marriage under Recognition of Customary Marriages Act – Requirement of mutual consent.
26 March 2024
Court ordered disclosure of forensic report under PAIA, finding respondent failed to prove confidentiality or private-body status.
Promotion of Access to Information Act – application for forensic report – whether record excluded by s7 where related proceedings concluded; Public v private body – whether State-owned company acted as public or private body when commissioning internal forensic report; PAIA thresholds – s11 (public body) v s50 (private body) and onus on requester; Grounds of refusal – mandatory breach-of-confidence exemption (s37/s65) requires evidentiary proof beyond mere confidentiality clause; Section 80(1) – judicial peek discretionary and unnecessary where holder fails to discharge onus.
22 March 2024
High Court appointed an independent curator ad litem and postponed parental-rights application pending best-interest reports.
Children’s Act – appointment of curator ad litem – investigation of best interests – Family Advocate to assist and report – overlap with Children’s Court appointment – postponement sine die; parties granted leave to supplement affidavits.
19 March 2024
Applicant failed to exhaust PAJA internal remedies and did not bring a timely review; application dismissed with costs.
Administrative law; PAJA s7(1)–(2) — duty to exhaust internal remedies; leave to appeal under FAIS; unreasonable delay and condonation; no exceptional circumstances for exemption; review and execution challenged but dismissed.
19 March 2024
Board not lawfully removed; court orders immediate payment under Service Delivery Agreement and confirms directors’ locus standi.
Municipal entities – removal of directors; interplay between Systems Act s 93G and Companies Act s 71; contractual default under Service Delivery Agreement; arbitration clause and court jurisdiction; joinder and necessary parties; urgency and locus standi.
19 March 2024
Court awarded damages for past and future income loss after accepting expert evidence and applying contingency deductions including reduced life expectancy.
Road Accident Fund – catastrophic amputation – assessment of past loss of income and future loss of earning capacity; reliance on admitted expert reports and actuarial certificate; pre-morbid earnings as basis for actuarial calculation; contingency deductions including diminished life expectancy; separation of past medical expenses (Rule 33(4)); costs including two counsel.
18 March 2024
Accused convicted of murder, attempted murder and firearm possession; POCA and certain counts not proven.
Criminal law – identification evidence and proof beyond reasonable doubt; alibi disclosed late – probative weight and adverse inferences; common purpose liability where co‑accused present, armed and associated with conduct; POCA ss 9(1)(a) and 9(2)(a) require subjective intent to promote a pattern of gang activity; duplication of firearm possession counts and failure of s220 admissions to establish a count.
7 March 2024