High Court of South Africa Eastern Cape, Port Elizabeth

305 judgments
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305 judgments
Citation
Judgment date
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
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
December 2022
An urgent interdict was granted preventing the Treasury from withholding a municipality's equitable share pending review.
Local government funding – equitable share – s214 Constitution and Division of Revenue Act – withholding of allocations; Interdict – requirements for interlocutory interdict; Urgency – condonation of non‑compliance with filing rules; Intergovernmental Relations Framework Act – s40 dispute invoked, no requirement to exhaust further s41 procedures before court; Review – rationality and lawfulness of administrative decision to withhold funds; Costs against state respondents including two counsel.
30 December 2022
Condonation refused and arbitration award upheld: arbitrator acted within powers and no gross irregularity proven.
Arbitration — Review of award — s 33(1) Arbitration Act — allegation of arbitrator exceeding powers or gross irregularity — misconduct threshold. Condonation — interests of justice — extent and cause of delay, prospects of success. Construction contracts — JBCC PBA — clause 26 (assessment/notice/determination) — submissions v evidence.
13 December 2022
Executor successfully obtained urgent mandament van spolie; PIE inapplicable because respondents did not occupy the property as their home.
Property law – mandament van spolie – requirements: prior peaceful possession and unlawful dispossession; restoration of possession. Urgency – spoliation proceedings as a speedy remedy; applicant’s prompt action and respondents’ acquiescence. Locus standi – executor’s authority to vindicate estate assets and sue on behalf of the estate. PIE – applicability limited to occupiers’ homes; PIE not engaged where occupiers do not use property as their home. Defence of abandonment – requires intention to abandon; mere absence or untidiness insufficient.
13 December 2022
Payment by a medical scheme does not absolve the Road Accident Fund from compensating admitted past medical expenses.
Road Accident Fund – past medical expenses – payments made by medical scheme – whether such payments must be deducted from RAF compensation – collateral benefits and double compensation – insurance nature of medical schemes – statutory interpretation of s18 RAF Act – subrogation/reimbursement rights of medical schemes.
1 December 2022
November 2022
Leave to appeal granted where another court may reasonably find differently on scope of duty of care and expert evidence.
Civil procedure – Application for leave to appeal – s 17(1)(a)(i) Superior Courts Act – reasonable prospects of success required, not certainty. Delict – Duty of care – scope of duty where defendant admits legal duty – effect on wrongfulness enquiry and negligence proof. Evidence – Expert conveyancer evidence – admissibility and weight where duty scope contested.
22 November 2022
Rescission refused — quantum properly determined on actuarial evidence; applicant failed to justify default.
Civil procedure – rescission of judgment – rule 42(1)(a) – whether order erroneously sought or granted in defendant's absence. Pleadings – rule 22(3) – distinction between admission and non-admission; non-admission may operate as denial where defendant lacks knowledge. Evidence – quantum of patrimonial loss – actuarial evidence may suffice; viva voce evidence of claimant not always required. Common law rescission – requirements: reasonable explanation for default, bona fides, and prima facie defence with prospects of success.
15 November 2022