High Court of South Africa KwaZulu-Natal, Pietermaritzburg - 2023

160 judgments

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160 judgments
Citation
Judgment date
December 2023
An intentional unlawful arrest is not an "accident" under s35 COIDA, so COIDA does not bar the employee's claim.
COIDA s35 — exclusivity — definition of "accident" — intentional/unlawful acts excluded; causal connection/"zone of risk" test; onus on employer to show injury arose out of employment; statutory interpretation in light of Khoza, MEG v ON and Churchill.
19 December 2023
An electronically signed instrument styled as a 'Guarantee' was held to be a principal guarantee, not a suretyship; advanced e-signature unnecessary.
Guarantee vs suretyship – interpretation of instrument using text, context and purpose – electronically signed guarantee – ECTA s13(1) advanced signature not required where instrument creates principal obligation – entitlement to judgment for bank.
19 December 2023
19 December 2023
Appellants convicted of murder on common purpose; life sentences reduced to 14 years due to substantial and compelling circumstances.
Criminal law – murder – common purpose and dolus eventualis – active association where multiple accused jointly assaulted victim leading to fatal skull fracture. Criminal procedure – sentencing – mandatory minimum life imprisonment under s 51(1) CLAA – substantial and compelling circumstances may justify deviation; appellate interference where trial court materially misdirected. Evidence – eyewitness and post‑mortem corroboration of blunt force injuries.
18 December 2023
Appeal dismissed: single‑witness and medical evidence supported convictions; no substantial and compelling circumstances for reduced sentence.
Criminal law – sexual offences – rape, sexual assault and kidnapping – single‑witness evidence and cautionary approach; corroboration by medical evidence; customary marriage and consent not a defence; sentencing – prescribed life sentence for multiple rapes; appellate interference only for misdirection or disproportionate sentence.
1 December 2023
November 2023
Late amendment alleging postnatal resuscitation failures refused as unsupported by evidence and prejudicial to the defendant.
Civil procedure — Pleadings — Amendment under Uniform Rule 28 — Late amendment during trial to allege postnatal sub‑optimal resuscitation — amendment refused where unsupported by evidence led, inconsistent with existing expert evidence, and likely to prejudice respondent; prejudice and contribution to real issues are decisive; costs ordered against applicant, taxable after final judgment.
28 November 2023
Arrear vehicle licence fees existing at liquidation form part of the concursus creditorum; traffic regulator is not a preferent creditor.
Company law – liquidation – concursus creditorum – proof of claims under Companies Act and Insolvency Act; Road Traffic Regulations reg 25(7) – licence refusal does not create preferent creditor status; registrars’ remedy versus statutory proof of claim; refund of penalties where refusal to renew caused unlawful penalty accrual.
27 November 2023
Whether the applicant validly exercised an option to purchase land despite its subsequent subdivision into four erven.
Option to purchase – validity of written exercise where subject land later subdivided; identity of merx unaffected by subsequent re-description; annexed draft agreement as offer, not destruction of acceptance; option price preserved despite separate offer to pay additional development costs; seller’s obligation to effect subdivision and compliance with approval conditions includes costs of services; conditional counterclaim required to secure payment of additional servicing costs.
27 November 2023
24 November 2023
Application to declare respondent vexatious dismissed for failure to prove persistent, groundless litigation.
Vexatious proceedings – section 2(1)(b) Vexatious Proceedings Act – requirement of persistence and absence of reasonable grounds; limitation of access to courts (s34) and justification under s36; relevance and distinction from Beinash v Ernst & Young; costs award including reserved costs.
23 November 2023
23 November 2023
Applicant obtained interdiction restraining pension payment pending the fund's final decision on withholding under s 37D(1)(b)(ii).
Pension Funds Act s 37D(1)(b)(ii) – withholding of benefits; interdictory relief – requisites for final interdict; Highveld Steel principle – purposive interpretation permitting withholding pending determination; availability of alternate remedies (Pensions Funds Adjudicator); preservation pending fund’s final decision.
23 November 2023
De bonis propriis costs require exceptional legal misconduct; none found, so the personal costs order was set aside.
Costs — de bonis propriis — personal costs order against legal representative — exceptional circumstances required — misdirection as to timeliness of recusal application — absence of reckless or egregious conduct — order set aside.
17 November 2023
Condonation granted and leave to appeal allowed where another court may differ on whether INEC validly called the elective conference.
Civil procedure – condonation for late filing of application for leave to appeal – interest of justice, degree of delay and prospects of success considered. Appeal – leave to appeal to Supreme Court of Appeal granted where another court might reach different conclusion on whether an interim party body validly called an elective conference. Internal party disputes – validity of elective national conference called by Interim National Executive Committee (INEC) and effect of deviations from party constitution. Procedural defences – acquiescence, peremption and brutum fulmen considered and not established. Costs – apportionment and inclusion of costs of two counsel where so employed.
17 November 2023
Court set aside dismissal, adjourned trial sine die and ordered de bonis propriis costs against respondents' attorney.
Procedure – adjournment by consent – Magistrate's Court Rule 31(1)(b)(i) and 31(4) – 15‑day notice requirement is peremptory; judicial discretion to refuse late consent adjournment. Procedure – exercise of discretion – trial court must distinguish parties’ conduct and not treat innocent party as equally to blame. Costs – de bonis propriis order – counsel’s egregious misleading and opportunistic conduct warrants personal costs order.
17 November 2023
Court finds likely spoliation but, exercising discretion on costs, orders each party to pay own costs.
Spoliation — urgent relief based on possession not title; Costs — judicial discretion to be exercised fairly; Uniform Rule 41A — non-compliance not automatically fatal; Choice of forum — litigant entitled to choose High Court; Self-help — unlawful and justifies urgent relief.
16 November 2023
Court awarded R2,513,541.35 for a child’s traumatic brain injury, accepting actuarial loss calculations and R1,250,000 general damages.
Road Accident Fund – Quantum – assessment of future loss of earnings based on actuarial calculations using mean of opposing industrial psychologists’ postulations; general damages for pediatric traumatic brain injury – appropriate comparative awards and reasoning; section 17(4) undertaking for future medical costs; entitlement to interest where interest not claimed and prescribed rate calculation (repurchase rate plus 3.5%).
16 November 2023
Reported
Court removes trustee for serious fiduciary breaches; rejects court-appointed administrator, reserving that power to the Master.
Trusts – removal of trustee under s 20(1) Trust Property Control Act – fiduciary duties – misappropriation, unauthorised payments, unilateral acts and litigating without authority; Master’s exclusive discretion under s 16(2) to investigate/appoint administrator – limits on High Court ordering appointment; intervention by beneficiary; costs de bonis propriis and attorney-and-client costs.
10 November 2023
Applicant’s dissatisfaction claim was timely; SAICE appointment of adjudicator valid and employer must comply with adjudication.
Construction contract – dispute resolution by adjudication – time‑bar under GCC clause 10.2 – cause of dissatisfaction arises on receipt of certified payment certificate; Ad‑hoc adjudication rules – nomination by SAICE – validity of SAICE appointment; jurisdiction to determine time‑bar issue where raised.
10 November 2023
Application to adduce further evidence under s 309B is for the trial court to decide and must be remitted for determination.
Criminal procedure – s 309B(5) Criminal Procedure Act – application to adduce further evidence – decision is for trial court, not appeal court; trial court must receive evidence and record findings (cogency, sufficiency, demeanour and credibility) per s 309B(5)(c)(ii). Post‑sentence mitigation evidence – exceptional reception but required for fair trial rights.
10 November 2023
Incomplete trial record did not prevent a fair appeal; convictions as co‑perpetrators and identification upheld; delay referred to DPP.
Criminal procedure – incomplete appeal record and adequacy for fair appeal; evidential assessment on appeal; participation (co‑perpetrator) versus common purpose; identification evidence — parade v dock identification; inordinate delay in appeal process.
10 November 2023
A sentence for operating a taxi without a permit was excessive; the accused’s sentence was partially suspended on review.
Criminal law – Sentencing – Review – Sentence inappropriate and inducing shock – Magistrate’s misdirection by over-emphasising general deterrence – Suspension of portion of sentence as permissible and proportional option – National Land Transport Act s.50(1).
10 November 2023
A single verbal exchange and an earlier dog-bite incident did not meet the statutory threshold for harassment; interim order discharged.
Protection from Harassment Act 17 of 2011 — definition and scope of "harassment"; objective test for harassment — serious fear, alarm or distress; requirement of course of conduct or single overwhelmingly oppressive act (Mnyandu v Padaychi); review of confirmed interim protection orders.
3 November 2023
No substantial and compelling circumstances found; imposed life for murder and concurrent prescribed terms for related offences.
Criminal law – Sentencing – Minimum sentences prescribed by Criminal Law Amendment Act – substantial and compelling circumstances (S v Malgas) – first offender status insufficient where offence is particularly grave – murder as part of group/common purpose – robbery with aggravating circumstances – concurrency of sentences (s 280(2) CPA) – lack of remorse – mercy limited.
3 November 2023
Whether dock ID and uncontested DNA proved identity; convictions and concurrent life sentences for rape of minors upheld.
Criminal law – Identification evidence – Dock identification to be approached with caution; admissible but of limited weight absent independent prior identification. Criminal law – DNA evidence – admissibility, chain of custody, and weight; DNA as circumstantial evidence requiring proper chain and interpretation. Criminal procedure – Pre-trial admissions – statements at pre-trial and in court as bearing on contested issues. Sentencing – Appellate restraint; interference only for material misdirection or shockingly inappropriate sentence. Sexual offences – Rape of minors; minimum sentence and gravity of predatory conduct.
3 November 2023
The applicant's appeal against convictions and life sentence for kidnapping and rape of a minor is dismissed.
Criminal law – sexual offences – rape of a child under 16; single‑witness evidence and cautionary approach; medical evidence and significance of genital injuries; definition of sexual penetration; minimum sentence life imprisonment under s 51(1) and Part I of Schedule 2; substantial and compelling circumstances; sentencing triad (Zinn).
3 November 2023
Appeal upheld: state failed to prove corruption or defeating ends of justice; accomplice evidence unreliable and charges duplicative.
Criminal law – Corruption – Elements and proof – requirement to prove public officer accepted or agreed to accept gratification to act or omit lawful duty beyond reasonable doubt. Evidence – Accomplice evidence – necessity to approach with caution where witness is unsatisfactory or inconsistent. Criminal procedure – Splitting of charges/duplication – when two charges arise from same composite conduct, prosecution must avoid unfair multiplicity. Criminal law – Defeating the ends of justice – omissions on admission-of-guilt notices (J534) do not alone prove intent to defeat prosecution.
3 November 2023
Identity proved by surveillance footage and eyewitnesses despite an imperfect identity parade; accused convicted on all counts.
Criminal law – identity – weight of identification parade evidence where parade participants not matched for complexion, facial marks or beard – reduced weight. Criminal law – corroboration – value of objective CCTV footage combined with eyewitness and police observations. Criminal law – common purpose – gang roles in armed robbery and foreseeable lethal risk leading to murder and attempted-murder liability.
2 November 2023
October 2023
Liquidator must act under the settlement agreement, stepping in only where attorneys failed to agree; no rectification ordered.
Contract interpretation; universal partnership dissolution; liquidator's appointment and mandate; whether mandate novates settlement agreement; annexure 'M' not a final ruling; timeousness of review; rectification of mandate; liquidation and distribution account; debatement.
29 October 2023
Court set aside adjudicator’s levy order for failure to consider contract, admitted unsigned agreement, and remitted matter to CSOS.
Community Schemes Ombud Service Act – appeal under s57 limited to questions of law; condonation for late appeal; admissibility and status of unsigned Agreement of Use and Occupation; adjudicator’s duty under s51 to obtain documents; adequacy of reasons under s54(1)(c); remittal versus substitution of administrative decision.
25 October 2023
Applicant’s inconsistent, unaudited financials rendered its bid non‑responsive; contract invalid and interim relief refused.
Public procurement – mandatory pre‑qualification criteria – audited financial statements – failure to comply renders bid non‑responsive; no power to condone pre‑emptory requirements; reactive (collateral) challenge by organ of state permissible to resist enforcement of unlawful award; interim relief requires prima facie right and prospects of success; punitive costs where applicant seeks to preserve unlawful status quo.
24 October 2023
Summary judgment refused where defendant’s perfunctory denial of possession nonetheless disclosed a bona fide triable defence.
Civil procedure – summary judgment — amended Uniform Rule 32 — assessment limited to whether plea discloses nature and grounds of defence and whether defence appears bona fide and good in law; rei vindicatio — owner must prove ownership, defendant's possession at commencement of action and identifiable thing; bare or perfunctory denials may be unacceptable drafting but can still raise triable issues; costs of summary judgment reserved for trial court.
20 October 2023
Police procured confessions irregularly; police, NDPP and trial court held jointly liable and damages to be apportioned; quantum postponed.
Police procedure – confessions vs warning statements – failure to use prescribed confession pro forma – confessions obtained by investigating officers treated as fatally defective; Malicious prosecution and delict – police acted without reasonable and probable cause and with animus; Prosecutorial and judicial negligence – contribution to unlawful detention; Apportionment of damages between police, NDPP and trial court; Quantum postponed sine die.
20 October 2023
Appeal dismissed; personal circumstances not substantial and compelling to depart from CLAA minimum sentences.
Sentencing appeal – prescribed minimum sentences (CLAA) – substantial and compelling circumstances – appellate interference standard – night‑time home invasion and multiple gunshot killing – genuine remorse requirement.
20 October 2023
Reported
A section 105A plea agreement that lacks required authorisation, consultation and judicial scrutiny is invalid; conviction set aside.
Criminal procedure – Plea bargaining – s105A CPA – requirements for valid plea and sentence agreement (prosecutor's written authorisation; consultation with investigating officer and complainant; accused's legal representation and confirmation; presiding officer's duty to ensure sentence is just); Distinction between s112(2) written pleas and s105A negotiated pleas; Review and setting aside of conviction and sentence for non-compliance.
20 October 2023
Reported
Public bodies failed to justify PAIA refusals; PEC secrecy and forensic reports not exempt, disclosure ordered (limited exceptions).
PAIA — burden under s81(3) — sufficiency of evidence; s7 exclusion for records sought for litigation; s44 (opinions/reports/minutes) and requirement that material was obtained to assist decision‑making under law; s23 (missing records) and s23(2) particularity; s12 Cabinet secrecy limited to national Cabinet; disclosure of interview audio and individual score sheets; protection of third‑party personal information under POPIA/PAIA.
19 October 2023
An authority challenge to litigation must be pursued under Rule 7(1); raising it first in an answering affidavit is fatal.
Corporate law – authority to institute litigation – Uniform Rule 7(1) – challenges to authority must be raised by rule 7(1) and not first by answering affidavit; Companies Act s75(5) – director’s disclosure and recusal; Eviction – commercial lease terminated for arrears – ejectment granted; Costs – attorney-and-client scale for dilatory or specious litigation conduct.
19 October 2023
Condonation for a late PAJA review and a last‑minute postponement were refused due to unjustified delay, weak prospects and likely mala fides.
Administrative law – PAJA s7 and s9 – condonation for late review – interests of justice: length and cause of delay, prospects of success, prejudice and effect on administration of justice; Civil procedure – postponement – discretionary refusal where explanation and timing inadequate; Professional conduct complaints – complaints to Legal Practice Council – review dismissed where complaints lack merit or are mala fide; Abuse of process – false allegations vitiating prospects of review.
18 October 2023
Court found no substantial and compelling circumstances to avoid prescribed minimum sentences; imposed life for murder and concurrent determinate terms.
Criminal law – sentencing – minimum sentences under Criminal Law Amendment Act – substantial and compelling circumstances – common purpose liability – youthfulness as mitigating factor – remorse – concurrency of sentences – no s103(1) Firearms Control Act order.
18 October 2023
Application to return child to private school struck off for lack of urgency; children's court is appropriate forum.
Urgency — Uniform Rule 6(12)(b) — self-created urgency; Children’s matters — best interests of the child (s 28(2) Constitution) — children’s court proper forum for disputes on care, contact and schooling; Interim relief — applicant must show inability to obtain substantial redress in due course.
18 October 2023
Summary judgment granted where defendants’ plea and affidavit were vague, contradictory and failed to disclose a bona fide defence.
Rule 32 – summary judgment – defendant must disclose a bona fide defence; amended Rule requires proper, detailed plea; vague, contradictory plea and affidavit may constitute a sham defence; reliance on Breitenbach and Maharaj; summary judgment appropriate where defence not substantiated.
17 October 2023
A member’s short-term letting rights under an MOI/Conduct Rules can be lawfully removed by a validly passed special resolution; adjudicator must consider MOI amendment legality.
Community schemes – CSOS Act s57 appeals limited to questions of law; adjudicator’s duty to consider relevant evidence (s50(c)). MOI amendments – requirements for special resolutions and valid voting; minutes and notice as determinative. Validity of AGM special resolution to amend MOI and Conduct Rules; board’s power to convene AGM under MOI. Vested rights – contractual rights under MOI/Conduct Rules can be altered by validly passed amendments.
17 October 2023
Circumstantial and fingerprint evidence supported an inference of common purpose, convicting all three accused of kidnapping, robbery, murder and attempted murder.
Criminal law – Kidnapping, robbery, murder and attempted murder – Circumstantial evidence and inference (R v Blom) – common purpose – admissibility and weight of fingerprint/palm-print evidence – consequences of accused electing silence – section 174 discharge – section 204 indemnity – criticism of inadequate police investigation.
16 October 2023
A prosecution may not review an acquittal based solely on dissatisfaction with the magistrate’s factual finding.
Criminal procedure – review versus appeal – acquittal finality; review to challenge legality/process not correctness; prosecution appeal limited to questions of law (s310(1)); double jeopardy protection; s174 discharge; absence of identified procedural irregularity defeats review.
13 October 2023
As‑is sale clause and lack of incorporated warranty defeat CPA and report‑based defences; summary judgment granted.
Contract — sale of used plant sold "as is"; exclusion clause precluding unwritten representations; Consumer Protection Act defence insufficiently pleaded and inapplicable; pre‑contract laboratory report not a contractual guarantee; summary judgment where no bona fide defence disclosed.
13 October 2023
Reported
Trustees who divert donor funds to themselves and associates in breach of trust may be removed and ordered to pay costs.
Trust law – removal of trustees – s 20(1) Trust Property Control Act – fiduciary duties (care, diligence, impartiality, conflict avoidance) – trustees’ discretion to distribute trust funds vs trust objects – improper distributions to trustees and related parties – costs on attorney-and-client scale.
13 October 2023
Court granted interim stay of councillors' expulsions pending review due to procedural irregularities and urgency.
Administrative law – procedural fairness – compliance with Rule 16(8) and s3 of PAJA – right to make submissions before removal. Interim relief – urgency, prospects of success, balance of convenience – stay of removal and interdiction of by-elections. Non-joinder – political parties not required where relief directly affects applicants. Intervention – leave granted to political party to intervene as respondent.
6 October 2023
Sequestration confirmed where unexplained transfers and trust/spouse dealings create a reasonable prospect of asset recovery for creditors.
Insolvency — s 12(1)(c) Insolvency Act — advantage to creditors assessed on a 'reason to believe' standard — unexplained transfers between company, director, spouse and family trust may justify sequestration to enable statutory investigation; provisional trustees have limited powers and paragraph in provisional order does not empower full enquiries; liquidation interrogations and referral to oral evidence are not always adequate substitutes; late affidavits and last-minute adjournments refused where they would not materially assist.
6 October 2023
Interim stay granted of councillor expulsion pending review due to procedural irregularity and urgency.
Administrative law – review and interim relief – urgency – procedural fairness in removal of municipal councillor; complaint-author participating in investigative committee; failure to interview affected councillor; balance of convenience; joinder and intervention.
6 October 2023
Practitioner justified winding up where an amended rescue plan failed and promised intra‑group funding never materialised.
Companies Act — business rescue — s141(2)(a)(ii) — practitioner must show reasonable grounds for conclusion no reasonable prospect of rescue (Oakdene standard) — Plascon‑Evans approach to disputed facts — failed rescue plan dependent on intra‑group capital injection — conditional, lapsed sale agreements not reliable — final liquidation appropriate — costs order against intervening creditor for opposition.
6 October 2023