High Court of South Africa KwaZulu-Natal, Pietermaritzburg

636 judgments

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636 judgments
Citation
Judgment date
March 2025
Court awards custody of both young siblings to mother, refuses consent order that perpetuated their separation; sets access for father.
Family law – custody and residence – best interests of the child – siblings should ordinarily be kept together; consent orders affecting minors scrutinised by court as upper guardian; weight of outdated expert reports; contact/access orders; parental alienation allegation considered but not proved.
13 March 2025
Damages awarded for birth-related negligence adjusted for unsupported medical treatments; certain awards reduced on appeal.
Damages for medical negligence leading to cerebral palsy – Adjustment of awards for future medical costs and significant penalties – Costs associated with speculative future treatments dismissed.
7 March 2025
Reported
Confession obtained in breach of constitutional right to prompt legal consultation rendered the conviction unsafe and was set aside.
Criminal law — confession — admissibility — accused’s right to remain silent and to consult legal practitioner promptly (s35 Constitution) — exclusion of evidence obtained in violation of Bill of Rights — judicial misdirection in credibility findings and finality of preliminary admissibility ruling — manifestly unsafe conviction where confession is sole incriminating evidence.
7 March 2025
Rescission dismissed where applicant had notice and failed to prove creditor status; final winding up granted for insolvent company.
Companies law – winding up – provisional winding-up confirmed as final where company is commercially and factually insolvent; rescission – Uniform Rule 42(1)(a) requires absence plus error and court retains discretion to refuse rescission; section 354 locus standi requires proof of creditor status; striking out affidavits requires scandalous/vexatious/irrelevant material; urgency must not be self-created.
4 March 2025
February 2025
Conviction set aside where trial court misdirected itself and failed to apply required caution to uncorroborated child evidence.
Criminal law – rape alleged against child – evaluation of single child witness evidence – requirement to approach uncorroborated child evidence with caution – misdirection by trial court treating as common cause the occurrence of the rape – medical J88 may be neutral on penetration – interpreter unsworn initially but subsequent swearing cured defect.
28 February 2025
Court set aside Master’s unlawful trustee appointments and dismissed applicants’ claim to reinstatement.
Trusts — communal property trust — Master’s powers under Trust Property Control Act — appointment and removal of trustees — limits where trust deed prescribes election process — lawfulness of letters of authority — review and setting aside of unauthorised trustee appointments.
26 February 2025
Failure to exhaust prescribed internal appeal remedies and mootness defeated a review of a municipal tender award.
Procurement law – municipal supply chain management – requirement to exhaust internal appeal remedies before judicial review; municipal accounting officer’s power to deviate from committee recommendations; responsiveness of tender documents (Central Firearm Registration); PAJA timing and mootness of remedial relief.
26 February 2025
Non-parole period improperly fixed without hearing; 25-year rape sentence correctly confirmed.
Criminal procedure – s 276B CPA – fixing non-parole periods – court must indicate intention, hear parties and give reasons; reserved for exceptional circumstances. Separation of powers – parole assessments ordinarily for parole authorities, not routinely for courts Sentencing – Zinn triad applied; appellate interference only for material misdirection or startling inappropriateness. Serious sexual offences – multiple rapes at knifepoint justify lengthy term; deviation from prescribed life can be lawful where reasons exist
24 February 2025
A state entity’s self-review was dismissed for reliance on hearsay and an unreasonable, unexplained delay.
Administrative law — Legality/self-review by state-owned entity — applicant must make case in founding affidavit; hearsay and late, minimal confirmatory affidavits insufficient — review must be brought without undue delay; long unexplained delay (≈1 400 days) unreasonable — discretion to condone delay not to be exercised where delay appears tactical or prejudicial — Plascon‑Evans principle applies to factual disputes in motion proceedings.
21 February 2025
Reported
Conviction confirmed; sentence reduced to R500 or 30 days; firearm disqualification set aside; magistrate's insulting conduct condemned.
Criminal procedure — s 112(1)(a) plea — exercise caution where accused is unrepresented; sentencing — fine versus alternative imprisonment — proportionality and competence under s112; Firearms Control Act s103(1) — disqualification requires listed offences or imprisonment without option of a fine; Judicial conduct — duty to treat accused with dignity; Review — sentence imposed by additional magistrate subject to section 302(1) review.
21 February 2025
A racecourse operator is entitled to 3% tax distributions for races specified in its licence; the regulator unlawfully withheld funds.
Gaming and betting — statutory interpretation of distribution of tax deductions — entitlement of racecourse operator to 3% distribution tied to races specified in licence — unlawful withholding of provincial funds by regulator; strike-out of scandalous affidavit averments; punitive costs where state acted unlawfully.
14 February 2025
Directors’ resolution confined to tax matters cannot be used to authorise commercial lease agreements; agent cannot delegate greater powers.
Company law – authority to bind company – directors’ resolution limited to tax affairs does not confer power to enter commercial contracts; agent cannot delegate more power than conferred; power of attorney cannot validate ultra vires delegation Agency – actual vs ostensible authority – party requiring proof of actual authority cannot later rely on ostensible authority Prescription – unjust-enrichment claim prescribed Reconvention – repayment of amounts withdrawn by debit orders, allowance for reasonable use of goods
7 February 2025
January 2025
Interdict preventing transfer set aside after subsequent judgment validated competing sale; transfer ordered and costs awarded.
Property law — Competing sale agreements and interdicts; validity of sale by non-registered owner; motion proceedings and Plascon-Evans approach to disputed facts; suspensive/resolutive conditions; misjoinder; transfer relief and costs.
31 January 2025
Confessions taken without proper rights-advice/interpretation and uncorroborated accomplice/dock ID evidence cannot sustain convictions.
Criminal law – Confessions – Admissibility under s 217 CPA and s 35 Constitution; voluntariness, proper informing of rights and interpretation; commissioned officer attached to investigating team taking confession; judicial notice and handwriting specimens; accomplice evidence and the cautionary rule; reliability of dock identification after mistaken identity at identification parade.
31 January 2025
Exception dismissed: amended particulars sufficiently pleaded; disputed factual and trust-piercing issues reserved for trial.
Civil procedure – exception under Uniform Rule 23(1) – pleading must disclose cause of action on its face; if evidence can be led to sustain claim, not excipiable; pleadings read as whole not piecemeal; allegations about origin and purpose of payments and nexus to defendant; challenge to declaratory relief piercing trust/alter-ego reserved for trial.
30 January 2025
Appellant failed to prove conveyancing error or valid transfer of exclusive-use parking bay; appeal dismissed with costs.
Sectional Titles Act — acquisition and transfer of exclusive use areas — pre-1997 transfers require registration by notarial deed of cession; bona fide purchaser protection; onus of proving conveyancing/deeds office error.
26 January 2025
Arbitration suspends prescription until finalisation; interim awards do not end the suspension.
• Arbitration law – interim awards – effect on arbitration process and enforceability.• Prescription – s 13(1)(f) – arbitration as impediment suspending prescription until finalisation.• Arbitration Act s 31 – making awards orders of court; interplay with Prescription Act.• Prescription Act s 13(2) (reciprocal debts) and set-off – requirement for close correlation and proper pleading.
24 January 2025
Condonation granted; rule 30A and rule 35(7) applications dismissed — discovery limited to material before the decision-maker.
Civil procedure — Rule 53 review — scope of review record; Rule 35(3)/(7) discovery not a vehicle for documents irrelevant to decision-maker’s record; Rule 30A — limits and proper use; condonation — requirements and adequate explanation; costs — attorney-and-client for abusive or unnecessary interlocutory litigation.
24 January 2025
Application to rectify sale agreement and compel performance dismissed due to genuine disputes of fact requiring action proceedings.
Contract - Rectification – generally competent only in action proceedings where common intention disputed and oral evidence required. Civil procedure - Motion proceedings – Plascon-Evans and Wightman principles; genuine disputes of fact on affidavits justify dismissal or referral to trial under Rule 6(5)(g). Suspensive conditions – non-fulfilment and lapse; effect of alleged extensions and timing disputes on contractual validity
24 January 2025
Loan agreement cancelled; respondents jointly and severally liable for R10,100,011.46 with securities executable and notarial bond perfected.
Large business loan – default and cancellation – certificate of balance as proof of indebtedness – suretyship: co‑principal debtor in solidum – special execution of immovable property – perfection of general notarial bond – interest subject to National Credit Act.
21 January 2025
Business rescue application dismissed for misleading non‑disclosure, procedural non‑compliance and no reasonable prospect of rescue.
Companies Act s 131 – business rescue application by affected person; requirement of reasonable prospect of rescue (Oakdene test); material non‑disclosure and bona fides; provisional liquidation suspends directors’ powers – trading without provisional liquidator’s consent; procedural notice requirements under s 131(2); consequences of speculative/unparticularised rescue allegations.
21 January 2025
Reported
A business rescue plan cannot extinguish post‑commencement tax debts without the creditor’s explicit accession.
Companies Act s152(4) – adopted business rescue plans binding as to enforceability; s154(2) – compulsory deprivation confined to pre‑commencement debts; s154(1) – creditor accession required to discharge post‑commencement debts; silence/absence not accession; Tax Administration Act requires formal written compromise by senior SARS official; no prima facie entitlement to interim interdict.
10 January 2025
Reported
Leave to appeal dismissed; attorneys disciplined with costs de bonis propriis for relying on incorrect or non-existent authorities.
Procedural law – leave to appeal – Superior Courts Act s 17(1) test for reasonable prospects of success and compelling reasons Civil procedure – reconsideration/rescission of orders – exercise of discretion; standards for appellate interference (Trencon principle) Service and disclosure – Uniform Rules on service, GLAA compliance and condonation; disclosure of prior related proceedings Professional conduct – duty of legal practitioners (and candidate practitioners) to verify authorities, not to mislead court; supervision obligations (Code of Conduct, rule 18.3) Use of AI in legal research – risks of fabricated/non-existent authorities; potential disciplinary consequences Costs – costs de bonis propriis for attorneys responsible for defective authorities and additional appearances
8 January 2025
Adjournment refusal stands absent misdirection; mero motu substitution invalid without exceptional circumstances—applications remitted for reconsideration.
Administrative law — judicial review — PAJA s 8(1)(c) — substitution orders permissible only in 'exceptional cases' — court should not mero motu substitute administrative decision absent exceptional circumstances or parties' pleadings; Civil procedure — postponement — appellate interference limited to cases where lower court misdirected or exercised discretion irrationally; Audi alteram partem — right to be heard infringed by unbidden substitution.
7 January 2025
December 2024
Putative self‑defence fails where the appellant lacked an honest reasonable belief and killed an unarmed person; conviction and sentence upheld.
Criminal law – Murder; putative private (self-)defence; distinction between private defence (objective) and putative defence (subjective); assessment of eyewitness credibility; dolus eventualis; sentencing discretion and substantial and compelling circumstances to depart from prescribed minimum.
20 December 2024
Leave to appeal refused where default was unjustified, service upheld, liability and insolvency established; rescission not bona fide.
Civil procedure – leave to appeal – Superior Courts Act s 17(1)(a): leave only where appeal would have reasonable prospects of success. Service of process – sheriff’s return of personal service carries prima facie validity; vague contrary evidence insufficient Banks Act – directive under s 83 can give rise to a deemed act of insolvency under s 83(3)(b); prior limitation under s 84 does not preclude reliance on s 83 directive Sequestration – insolvency and advantage to creditors may be established by repayment administrator’s report and property valuation (less encumbrance). Rescission for default – must be bona fide and accompanied by full, frank disclosure including prior unsuccessful review remedies
13 December 2024
Loss of support claim dismissed: lobolo and partial cohabitation did not establish a customary marriage or life-partnership entitlement.
Loss of support claim – customary marriage – lobolo payment alone insufficient – Recognition of Customary Marriages Act s3(1) and s10(4) – consent of first wife required – life partnership/relationship akin to marriage not established (Evins; Paixão; Jacobs; MM v MN; Mbungela).
6 December 2024
Arrest near a recently stolen vehicle based on camera-room information was reasonable; malicious prosecution claim failed.
Criminal procedure – Arrest without warrant – s40(1)(b) CPA – objective reasonableness of suspicion where suspects found near recently stolen vehicle identified via camera room/CCTV. Malicious prosecution – actio iniuriarum – requirement to prove animus injuriandi (intent to injure) or dolus eventualis; negligence insufficient. Prosecutorial discretion – reasonable and probable cause to prosecute pending further investigation; postponement to obtain statements, identification parades and CCTV review justified Bail – where Schedule 6 offence is involved, accused must show exceptional circumstances to obtain bail; duty to apply for bail rests with accused
2 December 2024
Indefinite section 77(6) detention in a prison hospital without periodic review was set aside; MHCA transfer ordered.
Criminal procedure – section 77(6) CPA – interim detention of accused unfit to stand trial – requirement for periodic review and limits on committal periods under section 79(2)(a) Review – High Court special review powers over magistrates’ detention orders where serious prejudice may ensue. Constitutional law – right to liberty – unlawfulness of indefinite detention in prison hospital pending psychiatric bed availability Mental Health Care Act – necessity of MHCA 23 designation and transfer in terms of section 53(2) for mentally ill prisoners
2 December 2024
November 2024
Appellant's challenge to bulk-meter domestic water charges dismissed; new commercial-billing claim raised too late.
Sectional title – bulk metering – municipal water tariffs – application of domestic sliding-scale tariff to a single bulk-metered scheme; procedural law – new case raised at hearing / not pleaded – inadmissible; municipal policy permits individual unit meters (owners’ cost); no constitutional attack advanced.
29 November 2024
Personal service or prior court-authorised substituted service is required before declaring residential property executable; appeal dismissed.
Rule 43A/46A – execution against residential immovable property; requirement of personal service or prior court authorisation for substituted service; judicial oversight over all residential property (primary or non-primary) to protect s 26 rights; notice and right to be heard; execution against sectional title units; application of Bestbier authority.
29 November 2024
Trial court erred in awarding quantum; insurer failed to prove misrepresentation or material non‑disclosure as cause of loss.
Insurance — liability only under Uniform Rule 33(4) — trial court erred in awarding quantum; Origin of fire — eyewitness evidence v expert reconstruction based on delayed post‑event inspection; Misrepresentation/non‑disclosure — materiality test under s 53(1) Short‑Term Insurance Act; Forensic testing of waste samples — smouldering v flaming risk; Post‑fire remediation not necessarily indicative of concealment.
29 November 2024
Reported
Appellant's challenges to conviction and sentence dismissed; trial court properly evaluated evidence, credibility, and sentencing discretion.
Criminal law – fraud, corruption, money laundering, PFMA contravention; disclosure of conflict of interest by procurement officials; ex tempore judgment—permissible editorial additions; credibility assessments and adverse inference from silence; sentence review and appellate restraint.
29 November 2024
Leave to appeal refused where written sale excluded extra-contractual warranties and no triable factual dispute existed.
Sale of goods – interpretation of written sale agreement – pyrolysis charcoal plant vs biochar – incorporation of prior reports – exclusion clauses barring extraneous representations – adequacy of evidence to resist summary judgment – requirement of pleaded, admissible facts to establish a bona fide defence.
28 November 2024
Court accepts social‑worker forensic evaluation, orders phased unsupervised contact, appoints curator and penalises applicant with costs.
Children — best interests paramount; urgency — self‑created urgency and degrees of urgency; forensic evaluation — competence of social‑work assessors versus psychologists; appointment of curator ad litem and social‑work coordinator; phased reintroduction of contact pending reports; punitive costs for late notice.
27 November 2024
An exception based on prescription and contractual interpretation failed where ambiguity required evidence and pleadings disclosed a cause of action.
Civil procedure – exception to particulars of claim – whether pleading discloses cause of action; benevolent interpretation of pleadings Prescription – contractual time‑bar clauses; prescription ordinarily pleaded by special plea; exception not appropriate where prescription does not plainly appear from particulars Contract law – interpretation of termination and main agreements; admissibility of surrounding circumstances and parties’ subsequent conduct; ambiguity precludes resolution on exception Costs – successful party on exception entitled to costs absent special features
26 November 2024
Court upheld life sentences for three rapes, rejecting pre-trial detention as sufficient cause to reduce prescribed minima.
Criminal law – sentencing discretion – prescribed minimum sentences – substantial and compelling circumstances – pre-sentencing detention not sufficient alone – correction of ambiguous sentence record; rape of minors; robbery with aggravating circumstances.
22 November 2024
Acting senior manager appointments are time‑limited; MEC may second a municipal manager and court authorised interim secondment under s172(1)(b).
Local government — Acting senior managers — Interpretation of ss 54A and 56 Systems Act — Acting appointments limited to three months; specific person may act further once (total six months) only with MEC extension — MEC may second municipal manager to advertised post under s54A(6) and chooses secondee — no equivalent secondment for CFO under s56 — appointments invalid where prescribed competencies lacking or misconduct/conflict present — s172(1)(b) remedial power to authorise interim secondment by MEC.
22 November 2024
Tender criteria and undisclosed two‑stage procurement were irrational and unconstitutional; awards and agreements set aside.
Administrative law – Procurement – Tender irregularities – Irrational functionality criteria requiring chartered accountants for multiple distinct disciplines; Two‑stage process not advertised; Failure to provide for price/preferential scoring; Remedies under PAJA and section 217 constitutional procurement duties; Internal remedies/exhaustion (MSA appeals and Municipal Bid Appeals Tribunal) ineffective where rights have accrued.
11 November 2024
A shareholder who approved annual financial statements cannot, without specific evidence of unfair prejudice, compel production of a company's accounting records under section 163.
Company law – s163 Companies Act – remedy for oppressive or unfairly prejudicial conduct – high threshold and requirement of specific, identifiable course of conduct causing objective prejudice. Shareholder inspection rights – s26(1)(c) – right to annual financial statements presented to AGMs; right to accounting records and source documents not automatic PAIA – alternative avenue for access to information not invoked by applicant Costs – punitive attorney-and-client costs appropriate where application is ill-founded and motivated by improper purposes
8 November 2024
Refusal to compel discovery of documents irrelevant to an actio iniuriarum claim is non-appealable; appeal dismissed with punitive costs.
Discovery – interlocutory orders – appealability under s83(b) and Zweni – refusal to compel discovery of documents irrelevant to actio iniuriarum – animus iniuriandi – post-event documents not generally probative – punitive costs for unmeritorious interlocutory conduct.
1 November 2024
October 2024
A purchaser at a sale in execution who accepts sale conditions can be liable for historic municipal debt beyond the two‑year rule.
Municipal rates clearance – sale in execution – s 118(1)(b) two‑year clearance versus s 118(3) historic debt – conditions of sale binding purchaser – municipality entitled to demand payment or guarantee or interdict transfer to secure municipal charge.
31 October 2024
Appellate court substituted two rape convictions with one multi‑occasion rape conviction and reduced sentence to 25 years.
Criminal law — Sexual offences — Consent vitiated by coercion and intoxication under SORMA; single‑witness evidence; first report and delay — s 59 SORMA Procedure — Charge framing: s 94 CPA (diverse occasions) versus multiple counts; s 106(4) entitlement to verdict; s 88 inapplicable to import common‑purpose findings Sentencing — Application of Schedule 2 Part I item (a)(i) CLAA (rape more than once); appellate interference where sentence disproportionate
29 October 2024
A defendant’s claim that a third party will pay instalments is not a bona fide defence to repossession.
Summary judgment — bona fide defence — oral evidence under Rule 32(4) — admissions of possession and arrears — third‑party payer allegation insufficient — National Credit Act s129 and certificate of balance compliance — repossession authorised.
28 October 2024
A sheriff lawfully executed a valid court order to seize property “where found”; no reasonable prospects of appeal.
Civil procedure – execution of court orders – sheriff authorised to attach and remove property “where found” – forcible entry to execute order. Constitutional law – limitation of rights (privacy, access to court) – justification under s36 – burden of factual proof on papers Rule 16 – notice of constitutional issues where respondents rely on court order Spoliation – not established where execution is pursuant to valid court order
22 October 2024
Arrest and detention lawful under s40(1)(a), malicious prosecution dismissed, but State liable for assault and costs on scale B.
Police powers – Arrest without warrant – s 40(1)(a) CPA – jurisdictional facts satisfied where officers present and fired upon; Detention – s 50 CPA – detention and guarded hospitalisation lawful where serious firearm offences; Assault – State vicariously liable where medical evidence and probabilities establish assault by arresting officers; Malicious prosecution – requires lack of reasonable and probable cause and animus injuriandi; Misdescription of party – substance over form where no prejudice; Costs – scale B, two counsel disallowed.
18 October 2024
Appellate court dismisses sentence appeal for deliberate theft of construction machinery; no material misdirection by trial court.
Criminal law – Theft of construction machinery – Sentencing – Appellate review of sentence – application of Malgas test; discretion of trial court; rejection of correctional supervision recommendation; weighing of mitigating factors and general deterrence.
18 October 2024
Court rules respondent could not terminate the contract before appeal completion based on explicit agreement terms.
Contract law – termination of contract – interpretation of contractual terms – impact of explicit contract terms over implied terms.
17 October 2024
Applicant misappropriated trust funds, failed to show full disclosure or genuine reformation, so readmission was refused.
Professional misconduct — misappropriation of trust funds; readmission — Kudo/Behrman/Swartzberg criteria; failure of full disclosure and inadequate repayment; credibility and remorse; costs awarded to regulatory body and Fidelity Fund.
14 October 2024
Plaintiff awarded R8.23m for loss of earnings and general damages; disability grant deducted from loss award.
Road Accident Fund – quantum – past and future loss of earnings – contingency (0.5% p.a.) and 5% past deduction – deduction of state disability grant as collateral source – general damages for severe traumatic brain injury and below-knee amputation – expert joint minutes and assessment of employability/probabilities.
14 October 2024