High Court of South Africa North Gauteng, Pretoria

The Gauteng Division of the High Court of South Africa is a superior court of law which has general jurisdiction over the South African province of Gauteng and the eastern part of North West province. The main seat of the division is at Pretoria, while a local seat at Johannesburg has concurrent jurisdiction over the southern parts of Gauteng. 

107 judgments
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107 judgments
Citation
Judgment date
May 2023
Plaintiff rendered quadriplegic by collision; RAF held 100% liable and ordered to pay loss of earnings, general damages and Section 17 undertaking.
Road Accident Fund – liability for injuries caused by negligent insured driver – defendant liable where third party negligence proven. Causation – ‘sine qua non’ and flexible approach; injuries (C3/C4 fractures) linked to collision. Quantum – admission of medico-legal reports under Rule 38(2); WPI 83%; actuarial computation and judicial discretion in assessing loss of earnings and general damages. Section 17(4)(a) undertaking for future medical/hospital accommodation and treatment.
31 May 2023
Winding-up application dismissed because bona fide disputes about indebtedness and lack of proof of inability to pay were shown.
Companies Act – winding-up – section 344(f) and 345(1)(a),(c) – creditor’s claim and demand prior to petitioning the court. Insolvency – commercial insolvency and inability to pay debts – requirement to show liquid assets to meet liabilities as they fall due. Civil procedure – bona fide disputes of fact on the papers – defeats compulsory liquidation; winding-up is a drastic discretionary remedy. Evidence – oral agreement and disputed invoices/payments raise material factual disputes not resolvable on affidavit.
31 May 2023
An oral agreement dividing immovable property can be enforced via a court‑appointed agent acting with written authority under section 2(1).
Civil procedure – exception – test on exception: whether on all possible readings no cause of action exists; Family law/estate division – deed of settlement appointing receiver/liquidator as agent to effect distribution; Property law – Alienation of Land Act s2(1) – requirement of written deed and written authority of agent; Specific performance – enforceability of oral agreement via court-appointed agent.
31 May 2023
Court awards R5,794,050 for future loss of earnings to minor after traumatic brain injury, applying a 25% contingency.
Road Accident Fund — admitted liability; dispute confined to quantum (future loss of earnings). Assessment of future loss of earnings for a minor — reliance on multidisciplinary expert evidence and actuarial valuation. Application of contingency deductions — child claimant, pre- and post-morbid trajectories, court discretion (25% applied). Section 17(4)(a) undertaking and establishment of trust for minor's award; general damages postponed sine die.
31 May 2023
Reported
Failure to provide Rule 49(13) security renders appeal steps irregular; Rule validly grounded in courts’ procedural and constitutional powers.
Civil procedure – appeals – Rule 49(13) – appellant required to enter into security for respondent's costs unless waived or court-ordered release; failure to comply renders appeal steps irregular. Rule-making power – Rules Board – procedural rules regulating practice and procedure validly promulgated; requirement for security grounded in courts' inherent/common-law powers and section 173 of the Constitution. Judicial discretion – court granting leave to appeal may release appellant wholly or partially from security obligation.
30 May 2023
Assessment of future loss for a minor with traumatic brain injury and post‑traumatic epilepsy; 25% contingency and RAF s17(4)(a) trust ordered.
Road Accident Fund — liability admitted; quantum only — future loss of earning capacity for a minor with traumatic brain injury and post‑traumatic epilepsy. Calculation of future loss — actuarial valuation, application of contingency deduction (court applied 25%). Section 17(4)(a) RAF undertaking — defendant to furnish undertaking for future treatment and trust administration costs. Default procedure/Rule 38(2) — court proceeded in defendant's absence to determine quantum. Trust for minor — trustees, security to Master and trust administration costs to be borne by defendant.
30 May 2023
Hague return application dismissed: habitual residence Canada, but return would expose child to an intolerable situation.
Hague Convention (Child Abduction) – habitual residence – Canada found to be child’s habitual residence. Article 12 – application within one year; Article 12(2) "settled" inquiry inapplicable. Acquiescence – absence of consent by left‑behind parent; prompt legal action. Article 13(b) – grave risk/intolerable situation – established on developmental/medical grounds. Expert evidence – duty to provide independent, reasoned opinions; inadequate expert report criticised. Costs – no order against Central Authority or left‑behind parent.
29 May 2023
Applicant failed to prove the insured driver’s negligence; claim dismissed with absolution from the instance.
Road Accident Fund – claim for loss of support – proof of negligence required to establish RAF liability Negligence – standard judged by totality of facts and conduct of reasonable driver (Rondalia) Sudden-emergency doctrine – split-second reactions may absolve driver of negligence (Ntsala) Evidentiary sufficiency – accident report and sworn statement assessed; plaintiff failed to establish liability
29 May 2023
Appellant's late postponement refused; Tax Court should have proceeded in appellant's absence and altered assessment under s129(2).
Tax — Postponement — discretionary refusal — bona fides, tardy notice, and prejudice — appellate interference limited. Tax — Tax Court jurisdiction — proceedings in absence of appellant — Rule 44(7) and s129(2)(b) TAA permit alteration of assessment on uncontested evidence. Withdrawal — absence of counsel not equivalent to formal withdrawal under Rule 46.
29 May 2023
Default judgment based on Rule 38(2) affidavits was not erroneously granted; rescission refused and costs awarded.
Civil procedure – rescission under Rule 42(1)(a) – default judgment – effect of notice of bar for failure to plead – proof by affidavit under Rule 38(2) permissible – requirement for mistake existing at time of judgment.
29 May 2023
Interim court protection against electricity disconnection remains until contractual/administrative dispute resolution is exhausted.
Electricity supply — interim interdict — effect of prior court order — requirement to exhaust contractual dispute-resolution processes (clause 31, Complaint Handling Process) — meter verification obligations — limits on termination under s21(5) Electricity Regulation Act.
26 May 2023
Whether the respondent is bound by rental agreements concluded by his agent and liable for amounts, interest and costs.
Agency – authority of agent (wife) to conclude contracts; Pleadings – requirement to plead lack of authority as a special defence; Evidence – proof of signature and delivery; Credibility findings; Rectification of contract commencement date; Costs – attorney and own client scale.
26 May 2023
Over a decade’s delay and nondisclosure precluded varying the divorce order to award half the respondent’s pension interest.
Family law — Divorce — Variation of final divorce order under Rule 42(1)(b) — Whether omission in original order justifying variation — Divorce Act s7(7) and s7(8) — Pension interests deemed part of joint estate; court may order pension fund to pay to non-member — Delay/laches and failure to disclose estate particulars — Exercise of judicial discretion to refuse relief.
26 May 2023
Variation of decade‑old divorce order for half of respondent's pension denied due to delay and insufficient evidence.
Divorce – variation of final order – Rule 42(1)(b) – omission/ambiguity/patent error – section 7(7) and 7(8) Divorce Act – pension interests deemed part of joint estate; court may order pension fund to pay non‑member spouse – inordinate delay/condonation – need for disclosure of joint estate and both spouses’ pension interests; discretion to refuse relief where prejudice and insufficient evidence exist.
26 May 2023
Arrest without warrant was lawful where a prior registered Schedule 1 complaint and superior’s instruction supplied reasonable suspicion.
Unlawful arrest; s 40(1)(b) Criminal Procedure Act; reasonable suspicion and reasonable grounds; arrest on superior's instruction; no duty to investigate or read complainant's statement before arrest; Schedule 1 offences; bona fide arrest and detention.
26 May 2023
An RAF appeal decision was set aside where the tribunal lacked appropriate medical expertise and acted unfairly.
Administrative law – Review of Road Accident Fund Appeal Tribunal decision – Tribunal composition – Regulation 3(8)(b) requires medical practitioners with expertise appropriate to the injuries (psychiatry where psychiatric injury alleged).; Consideration of irrelevant material – reliance on orthopaedic report for psychiatric injury and failure to follow RAF4/ narrative-test procedure.; Procedural fairness and bias – Tribunal’s refusal of further assessment, failure to allow appropriate expert participation and statements suggesting partiality – review and remittal ordered.; Remedy – decision set aside and rehearing by properly constituted Appeal Tribunal.
26 May 2023
A mere unilateral withdrawal of consent does not prevent a valid settlement agreed in litigation from being made an order of court.
Civil procedure – settlement agreements – incorporation of settlement into court order where parties agreed compromise; Eke criteria for incorporation; unilateral withdrawal of consent (change of mind) does not prevent enforcement where validity not attacked; pacta sunt servanda and abuse of process justifying punitive costs.
26 May 2023
Leave to appeal granted to clarify tariff classification under TH73.04, especially "alloy" and "of a kind" issues.
Customs & Excise – Tariff classification – TH73.04 – Interpretation of "alloy"/"non‑alloy" – Meaning of "of a kind used for oil or gas pipelines" – Leave to appeal under s17(1)(a)(ii) Superior Courts Act to clarify classification principles.
26 May 2023
Review of tender award dismissed for lack of factual irregularity, PAIA non-compliance, and failure to show material prejudice.
Procurement law – review of tender award; PPPFA and PAJA grounds; PAIA procedural compliance and internal remedies; Rule 53 disclosure; requirement to file answering affidavit; Allpay materiality test for tender irregularities.
26 May 2023
Leave to appeal convictions granted due to concerns about admissibility and sufficiency of evidence; leave to appeal sentences refused.
Criminal law – confession – admissibility – section 219 Criminal Procedure Act prohibits one person’s confession being admissible against another; passive assent (nodding) cannot be treated as confession without supporting authority. Evidence – robbery – insufficiency where property merely found missing after the killing with no proof of prior possession or removal by accused. Appeal procedure – prospects of success test (Smith v The State) – leave to appeal convictions granted, leave to appeal sentences refused.
26 May 2023
Whether joint‑possession convictions and the 25‑year robbery sentence are appealable, and whether accomplice and phone‑analysis evidence were properly admitted.
Criminal law – robbery with aggravating circumstances and use of explosives – common purpose liability and proof beyond reasonable doubt. Evidence – accomplice evidence (section 204 witnesses) – inconsistencies do not automatically render testimony unreliable; cautionary approach applied where appropriate. Evidence – admissibility and reliance on private cellphone/telecommunications analyst (former police officer employed by complainant). Criminal law – joint possession of firearms and ammunition – test requires exclusion of reasonable inferences other than joint possession; prospects of appeal on those counts exist where accused was not at the scene. Sentencing – prescribed minimum sentences, proportionality and whether a 25‑year sentence induces a sense of shock.
26 May 2023
Leave to appeal refused: applicant lacked realistic prospects of success and filed contradictory affidavits.
Appeal — leave to appeal — section 17 Superior Courts Act — heightened threshold: real prospects of success required; contradictory affidavit evidence undermines prospects; costs on attorney-and-client scale.
25 May 2023
Appeal dismissed: probabilities and lack of corroborative/ballistic evidence support respondent’s accidental‑discharge defence.
Delict — Alleged assault and shooting by police officer; mutually destructive versions resolved on probabilities; accidental discharge pleaded vs self‑defence; need for ballistic expert evidence to determine trajectory; corroboration and credibility assessed against conduct (flight/resistance).
25 May 2023
Share transfer void for lack of CPA-authority; lis pendens defence rejected; defective removal notice precluded compulsory meeting.
Communal property association — authority to dispose of immovable property — CPA constitution and s 12 CPA Act require special resolution at properly convened special general meeting (voting by heads of household); purported share transfer void for lack of authority. Lis alibi pendens — prior action concerning loan enforcement not substantially identical or determinative of present challenge to share transfer; discretion to hear urgent/separable issue. Companies Act — s61(3)/s71 demand to convene meeting to remove directors must include a statement of reasons with sufficient specificity; defective demand cannot be compelled by court. Costs awarded to successful applicant.
25 May 2023
Applicant proved sale and unpaid invoices; no bona fide factual dispute of a tacit medical‑quality term; first respondent ordered to pay R2,000,000.
Contract – sale of goods – claim for payment of invoices; dispute of fact on motion – Plascon‑Evans/Room Hire principles; tacit/implied term – fitness for medical purpose; evidentiary value of test reports/hearsay; liability of second respondent.
25 May 2023
Applicant awarded R650,000 general damages after court weighed contradictory expert reports on arm, spinal and mild head injuries.
Road Accident Fund – assessment and quantification of general damages – evaluation and weighing of contradictory expert evidence (orthopaedic, spinal and head injury reports) – relevance of signed, field-appropriate expert opinions – use of comparable awards in quantum assessment.
25 May 2023
Accident-related neurological, ophthalmic and psychological injuries materially reduced earning capacity; court awarded R2,010,716.65.
Road Accident Fund – loss of earnings – causal link between accident-related head, ocular and psychological injuries and diminished earning capacity – actuarial quantification – court’s discretion on contingency deductions (20%/10% applied) – award of R2,010,716.65 plus costs.
25 May 2023
An incomplete, improperly reconstructed trial record infringed the appellants' right to a fair appeal; conviction set aside.
Criminal procedure – Reconstruction of trial record – Incomplete reconstructed record containing missing evidence in chief and cross‑examination – Right to a fair trial and fair appeal – Lost magistrate notes and unavailable prosecutor – Improper reconstruction – Conviction and sentence set aside.
25 May 2023
Applicant granted direct leave to appeal to the SCA due to conflicting interpretation of Prevance regarding Fidelity Fund exclusions.
• Civil procedure – Leave to appeal – s17(1)(a)(ii) Superior Courts Act – compelling reason where conflicting interpretations of binding SCA authority exist; • Attorneys Act – ss26(a) (entrustment) and 47(1)(g), 47(5)(b) (Fidelity Fund exclusion) – whether exclusions and entrustment were correctly applied/determined; • Appeal route – direct grant of leave to SCA appropriate where SCA precedent at issue.
24 May 2023
Delay in reporting by a child does not preclude conviction; life sentence upheld absent substantial and compelling circumstances.
Criminal law – Sexual offences – Rape of child under 16 – Delay in reporting does not automatically undermine credibility (s 59 SOA); corroboration and J88 admissible. Evidentiary issues – Threats, authority and vulnerability can explain delayed reporting; false-implication defence rejected where contradicted by witnesses. Sentencing – Mandatory life sentence under s 51(1) read with Part 1 of Schedule 2; no substantial and compelling circumstances to deviate (Malgas/Dodo principles).
24 May 2023
A negotiated 1% per week bridging rate was not usurious; loan agreements enforceable and judgment granted with execution and rental cession.
Usury — common-law test requires proof of extortion, oppression or conduct akin to fraud; high nominal rates are not per se usurious; bridging finance — market-related high rates may be enforceable; constitutional challenge to contract terms (ss 22, 25) rejected where no infringement shown; security enforcement and cession of rentals upheld; costs on attorney-and-client scale.
23 May 2023
Unsigned subcontract can be binding by conduct; director not personally liable absent proper pleaded basis.
Contract law – formation: unsigned written documents can be binding where conduct shows agreement; ticket/quasi-assent principles applied. Pleading: particulars must disclose causa and not be vague or embarrassing. Vicarious liability: not a basis to impose personal contractual liability on a director acting as agent absent pleaded facts or delict. Joint and several liability: must be expressly pleaded or factually established to displace presumption of joint liability.
23 May 2023
Court set aside executrix appointment on fairness grounds; Master’s letter was not a PAJA-reviewable s54(2) notice.
Administration of Estates Act s54 – removal of executor – scope of Master’s powers and court’s power to remove an executor; notice requirement under s54(2). Administrative law – applicability of Promotion of Administrative Justice Act (PAJA) to Master’s alleged failure to decide; letter not a s54(2) notice and PAJA inapplicable. Executors – test for removal by court: dishonesty, gross inefficiency or untrustworthiness likely to prejudice estate; mere bigamy-based appointment error insufficient. Equity and fairness – hostility between interested parties and fairness to beneficiaries can justify setting aside an executrix’s appointment where continuation may prejudice estate administration.
23 May 2023
Service at a close corporation’s registered office is valid and its registered office confers High Court jurisdiction.
Close corporations — service at registered office valid under s25(2) Close Corporations Act and Rule 4(1)(a)(v); domicilium citandi does not preclude other lawful service; registered office confers jurisdiction; dual jurisdiction principle applies to close corporations; section 34 access to courts supports dual jurisdiction.
23 May 2023
An unnecessary Rule 35(7) application after discovery was provided amounted to abuse; applicant ordered to pay attorney‑and‑client costs.
Rule 35(7) — discretionary remedy; sub‑rules (1) and (3) must be exhausted before invoking (7). Costs de bonis propriis — prior notice to legal representatives required; exceptional conduct required to justify punitive costs. Abuse of process — unnecessary interlocutory application and prolix filings may attract attorney‑and‑client costs.
23 May 2023
Court reinstated review order and awarded costs after respondent failed to file answering affidavit and unjustifiably delayed opposition.
Administrative law – Judicial review – Decision to re-run internal election – Decision reviewable where premised on erroneous factual/legal basis; Civil procedure – Defaulting respondent granted indulgence to oppose subject to filing affidavit – failure to comply justifies upliftment of suspension and costs; Judicial discretion – refusal of further postponement where no prospects of success or prejudice shown.
23 May 2023
Appellate court reduced rape sentence due to appellant's intellectual impairment and manipulation, upheld concurrent porn distribution sentence.
Criminal law – sentencing – appeal against sentence – misdirection by sentencing court – appellate interference justified where discretion exercised unreasonably. Sentencing – minimum and prescribed sentences for rape of a minor – consideration of substantial and compelling circumstances. Mitigation – intellectual impairment and susceptibility to manipulation as factors reducing blameworthiness. Distribution of child pornography – sentence affirmed; concurrent ordering of sentences (s 280 CPA). Plea in terms of s 112(2) CPA – admissible plea explanation and its relevance to sentencing.
23 May 2023
Appellate court upheld robbery conviction but found no proof of grievous bodily harm, reducing sentence from 15 to five years.
Criminal law – Robbery – elements and single-witness evidence – caution in convicting on single witness but permissible if properly evaluated. Aggravating circumstances – grievous bodily harm – requirement of medical or sufficient evidence to invoke minimum sentencing under s51(2) Criminal Law Amendment Act. Minimum sentences – where aggravating circumstances not proved, prescribed minimum does not apply and sentence must be reconsidered. Sentencing – application of triad (crime, offender, society), mitigation, previous convictions, time already served and antedating of sentence.
23 May 2023
Leave to appeal granted because factual and credibility disputes raise reasonable prospects another court may decide differently.
Leave to appeal — defamation and retraction orders — final vs interim interdict — material disputes of fact on affidavit — applicability of National Credit Act to juristic person transactions — rescission of consent order (Rule 42) and inordinate delay — compelling reasons and prospects of success for leave to appeal.
23 May 2023
Pretoria High Court has jurisdiction to review municipal trustee appointments where the Master in Pretoria effected the appointments.
Administrative law – judicial review – jurisdiction – effect of Master of the High Court’s appointment of trustees – section 21(2) Superior Courts Act – locus of trust records and domicilium citandi relevant to jurisdictional connection.
22 May 2023
A public school was liable for learners' injuries from a collapsing gate due to negligent construction, oversight and supervision.
Public school liability; vicarious liability of MEC for school staff; duty of care and supervision of learners; construction defects and non‑compliance with SANS 10‑400; site safety and quality control; causation for injuries from collapsing gate.
22 May 2023
Leave to appeal granted where applicant raised triable issues and there was a reasonable prospect a full bench might differ.
Civil procedure – Leave to appeal – Section 17(1) Superior Courts Act 10 of 2013 – elevated threshold ('would' have reasonable prospects) – leave granted where triable issues and reasonable prospect another court may differ. Rescission applications – assessment of factual matrix and proper application of rules. References to Housing Protection Measures Act and National Home Builders Registration Council raised but determination left for appeal.
22 May 2023
Writ of execution for minor-children maintenance set aside where children attained majority and respondent lacked locus standi to enforce post-majority sums.
Family law – maintenance orders – effect of children attaining majority; enforcement – writ of execution issued by Registrar must conform to operative court order; locus standi – adult children have standing to claim maintenance themselves; Registrar’s duty to interrogate writ; continuity of maintenance after majority limited to necessaries and requires fresh enquiry.
19 May 2023
Whether the respondent is liable for injuries when the applicant was pushed from a moving train with open doors.
Rail operator duty of care – commuter safety – open carriage doors and lookout duties of metro guards – negligent omission – vicarious liability – causation established – contributory negligence not proved (Mashongwa applied).
19 May 2023
Contract for state procurement breached PFMA/s217; MRA declared invalid ab initio and plaintiff’s claim dismissed.
Public procurement — s 217 Constitution & PFMA s 38(1)(iii) — requirement for fair, equitable, transparent, competitive and cost‑effective system; security cession (cession in securitatem indebiti) — pledge vs fiduciary theories and effect on cedent’s rights and locus; contract termination and effect of lawful cancellation; constitutional remedy under s 172(1) — declaration of invalidity and just and equitable remedial orders.
19 May 2023
Late PAJA review dismissed: applicant’s deliberate non‑participation, lack of evidence of bad faith, and inordinate delay led to refusal of condonation.
Administrative law — PAJA review — delay and condonation — 180‑day rule — adequacy of explanation for delay and prospects of success; Employment removal — statutory power of Board under s 21(4) FAIS Act to remove deputy ombud for misbehaviour/incapacity/incompetence; Procedural fairness — audi alteram partem and consequences of deliberate non‑participation in disciplinary enquiry; Ulterior motive/unauthorised dictates — insufficient evidence to impugn decision; Rationality — decision rationally connected to enquiry findings.
19 May 2023
Appeal against life sentence dismissed; appellant's mitigation insufficient to constitute substantial and compelling circumstances.
Sentencing — Minimum prescribed sentence of life imprisonment for murder — Requirement of substantial and compelling circumstances to deviate — Appellate interference only for misdirection or manifestly disproportionate sentence — Common purpose and joint participation in drugging, robbery and resultant death.
19 May 2023
Bars and the GCB retain common-law standing to investigate and institute striking-off proceedings despite the LPA; advisory note not reviewable under PAJA.
Legal Practice Act – transitional arrangements – interpretation of s116(1)-(2) vis-à-vis common-law standing of Bars; Administrative law – PAJA – whether advisory note constituted administrative action; Inherent jurisdiction – High Court’s power to adjudicate disciplinary matters and to determine applicant standing; Custos morum – LPC is primary regulator but not exclusive; Concurrent jurisdiction – Bars and GCB may investigate and initiate striking-off applications (subject to Court’s control).
19 May 2023
Applicant granted urgent interdict preventing tenant’s illegal electricity reconnection; disconnection did not constitute spoliation.
Urgent application – landlord as electricity reseller – lawful disconnection for non-payment – illegal reconnection by tenant – mandament van spolie inapplicable to electricity disconnection – procedural deficiency of counterclaim.
18 May 2023
Reported
A section 131(6) business rescue order suspends but does not terminate liquidation; post‑liquidation dispositions remain void.
Companies Act s131(6) – effect of business rescue order on existing liquidation; suspension not termination; concursus creditorum remains intact; dispositions after final winding‑up void ab initio (s341(2)) and cannot be validated by subsequent business rescue.
18 May 2023