Land Claims Court of South Africa

The Land Court was established in 1996. The Land Claims Court specialises in dealing with disputes that arise out of laws that underpin South Africa's land reform initiative. These include the Restitution of Land Rights Act, 1994, the Land Reform (Labour Tenants) Act, 1996 and the Extension of Security of Tenure Act, 1997.

The Land Court has the same status as any High Court. Any appeal against a decision of the Land Court lies with the Supreme Court of Appeal, and if appropriate, to the Constitutional Court. The Land Court can hold hearings in any part of the country if it thinks this will make it more accessible and it can conduct its proceedings in an informal way if this is appropriate, although its main seat is in Randburg, Johannesburg, South Africa.

The court also deals with the Extension of Security Tenure Act* and the Labour Tenants Act*. These two acts were enacted by parliament to protect farm dwellers/workers from ill treatment and illegal evictions. The Land Court was conferred with the jurisdiction thereof. However the various magistrate courts around the country also have jurisdiction in terms of the Extension of Security Tenure Act although their orders pertaining evictions are subject to automatic reviews by this court. Primarily, the court has to ensure that the rights of farm workers/dwellers are protected in that all evictions are done within the framework of the aforementioned legislation.

* Restitution of Land Rights Act, 1994 (Act 22 of 1994)
* Land Reform (Labour Tenants) Act, 1996 (Act 3 of 1996)
* Extension of Security of Tenure Act, 1997 (Act 62 of 1997)

24 judgments
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24 judgments
Citation
Judgment date
December 2021
Appeal upheld: material disputes of fact required oral evidence and damages awards were unsupported.
Land‑tenure/eviction — Extension of Security of Tenure Act context — final relief on affidavit — material disputes of fact — Wightman/Plascon‑Evans test — duty to call oral evidence — inadmissible/new material in replying affidavit — unsustained damages awards without valuation/receipts.
9 December 2021
Court issued a rule nisi to interdict transfer and eviction pending resolution of a 2014 land claim and disclosure of award information.
Restitution of Land Rights Act – interim interdicts under section 6(3) – protection pending finalisation of lodged claims. Effect of LAMOSA decisions on processing and adjudication of claims lodged between 1 July 2014 and 28 July 2016 – limited protective relief available to new claimants. Locus standi of new claimants to seek procedural or preservative relief. Administrative law – access to information and fair administrative action by land claims authorities.
1 December 2021
November 2021
Leave to appeal a costs order refused; judge’s discretion to award costs for applicants’ conduct upheld.
Costs — judicial discretion to award costs for misconduct — persistent unproven allegations against presiding judge — locus standi to oppose recusal — leave to appeal; no reasonable prospects of success.
22 November 2021
The court granted occupiers’ condonation and leave to cross-appeal due to funding delay and strong res judicata prospects.
Land Claims Court – condonation for late application to cross-appeal – Melane factors – funding delays; Leave to cross-appeal – res judicata vs lis alibi pendens – ‘same persons’ requirement not strictly literal; Abuse of process/forum shopping – relevance to prospects of success; Costs on appeal.
11 November 2021
October 2021
Applicant's review was dismissed as premature because no final administrative decision had been taken and the land claim remains under investigation.
Restitution of Land Rights Act – review – competence and prematurity of review applications where no final administrative decision has been taken; publication and amendment of Gazette notices; challenge to prior State land purchases/transfers under PLA/LRAD; relief for deregistration and transfer contingent on final claim determination.
6 October 2021
An interdicted claimant may obtain an interim interdict to protect its interest in claimed land pending finalisation of the claim.
Restitution law – interim interdicts – locus standi of interdicted claimants; effect of LAMOSA judgments on protective relief; section 6(3) Restitution Act requirements; preservation of status quo pending finalisation of land claims; enforcement by sheriff and police.
1 October 2021
September 2021
Court accepts uncontested allegations of misprocessing of a land claim, orders subpoenas and documentary production under s28F to investigate validity of a s42D agreement.
Restitution of Land Rights Act — validity of s42D agreements — claimant status and prerequisites for implementation; Communal Property Association constitutionality and membership; obligation of Commission and RLCC to act with accountability and transparency under s195 of the Constitution; court’s power to subpoena and compel production under s28F; consequences of non-compliance with court orders and potential referral to prosecuting authorities.
30 September 2021
A village established under a utility’s statutory powers is a township excluded from ESTA, so eviction disputes fall under PIE.
Property law – Determination whether land developed by a public utility constitutes a ‘township’ for ESTA s2(1) purposes – Electricity Act s4 enables establishment/recognition of utility villages as townships. Jurisdiction – Land Claims Court lacks jurisdiction where matter is governed by PIE rather than ESTA. Eviction law – Distinction between remedies under ESTA and PIE; disputes of fact on alleged spoliation require adjudication in competent forum. Urgency – Criteria for spoliation-based urgent relief and when offers of alternate accommodation dissipate urgency.
17 September 2021
An occupier’s ESTA right to human dignity can include electricity installation; owner’s consent cannot unreasonably prevent it.
ESTA s5(a) – right to human dignity – improvements reasonably necessary to render dwelling habitable – electricity as a necessary improvement. Owner's consent – not a prerequisite for occupier to make necessary habitability improvements; meaningful engagement required. Constitutional and municipal law context – electricity as an implicit component of adequate housing/municipal services. Relief – order compelling consent to connection and interlocutory interdiction; costs awarded for exceptional intransigence.
7 September 2021
August 2021
Leave to appeal refused where applicant repeated prior arguments, conceded ESTA authority, and caused wasted costs by late filings.
Civil procedure – leave to appeal – section 17(1)(a)(i) and (ii) Superior Courts Act – reasonable prospects of success and compelling reasons required. ESTA – compliance with ss8 and 9(2); s8(1)(e) and binding authority of Snydos. Appealability – challenge to factual findings insufficient where no new grounds advanced. Costs – wasted costs awarded for non-compliance with practice directive (late heads of argument).
23 August 2021
Whether an occupier may erect a brick dwelling within a demarcated portion without owner’s consent, and the need for meaningful engagement.
Land tenure – ESTA – occupier’s rights to improve dwelling within demarcated portion – whether brick rebuilding constitutes an improvement/improved rebuild under Daniels v Scribante – consent v meaningful engagement – encroachment defined.
4 August 2021
Condonation refused and leave to appeal struck from the roll; no prima facie right to an interim interdict.
Land restitution — application for leave to appeal — condonation for late filing — applicant's delay and explanations inadequate; no prospects of success. Interim interdict — requirements: prima facie right and irreparable harm — not established. Publication in Government Gazette determines properties subject to claim; sale of claimed land not automatically void — s11(7) Restitution Act; mala fides required to set transaction aside. Costs — special circumstances justified departure from usual rule.
4 August 2021
Condonation refused and leave to appeal struck off; applicant failed to prove prima facie right or justify late filing.
Civil procedure — condonation for late filing — explanation for delay — inadequacy of blaming prior attorney and COVID-19 — United Plant Hire factors. Interim interdict — requirements (prima facie right; apprehension of irreparable harm) — Setlogelo applied — applicant failed to show entitlement. Restitution of Land Rights Act s11(7) — publication of land claim in Government Gazette does not determine merit; sale/development not per se void; notice to RLCC and court discretion where mala fides. Evidence — Government Gazette authoritative for identifying properties subject to claim; absence from Gazette undermines applicant's assertion.
4 August 2021
July 2021
Applicant’s urgent interdict to stop land clearing failed for lack of s 6(3) notice, evidence of defeat of restitution objectives, and balance of convenience.
Restitution Act (s 6(3), s 11(2) & s 11(7)) – interim interdicts – requirements for relief – interested party, reasonable belief development will defeat Act’s objects, notice and judicial discretion (s 33). Urgency – inherent urgency where clearing is in progress but urgency alone insufficient. Locus and authority of CPA to act for claimant community. Balance of convenience and irreparable harm – equitable redress alternatives and public interest in development. Costs – costs order appropriate where parties are commercially active.
30 July 2021
28 July 2021
May 2021
Reported
Court held that inspection minutes must record and attribute parties’ statements, which may amount to judicial admissions, and set a process to finalise them.
Inspection in loco — recording and transcription of statements — curial statements and potential judicial admissions — identification of party contentions and sources — procedure to resolve transcription disputes and finalise minute.
19 May 2021
s 18(3) relief requires a valid notice of appeal; a pending condonation does not suspend the judgment, so enforcement remains possible.
Superior Courts Act s 18 — suspension of decisions pending appeal — prerequisite that a valid notice of appeal be lodged in terms of the rules — pending condonation for late noting does not suspend judgment — where notice of appeal lapsed, no order under s 18(3) available; judgment remains enforceable — urgency and assessment of irreparable harm where order is time-limited (obiter).
17 May 2021
State ordered to pay substantial costs for failing to comply with court directives and Practice Direction 8(4).
Costs — Restitution claims — Failure by State/State Attorney to comply with court directives and Practice Direction 8(4) — entitlement to attorney-and-client costs — limits on counsel fees — systemic delays in finalising old claims and reporting obligations under LAMOSA.
12 May 2021
April 2021
Eviction under ESTA requires clear pleaded termination and direct opportunity to make representations for all occupiers.
Land tenure – Extension of Security of Tenure Act (ESTA) – Eviction applications – Requirement that right of residence be terminated in terms of s8 and that occupiers be afforded effective opportunity to make representations – Adult non-dependent children and spouses as occupiers in their own right – Compliance with s9(2)(d) notice requirements – Distinct requirements of ss10 and 11 – Supplementary affidavit cannot cure foundational omissions in founding affidavit.
13 April 2021
Challenge to an AGM, its elections and terminations dismissed; applicant lacked authority and costs awarded on attorney-and-client scale.
Communal Property Association — validity of AGM and committee elections — notice and quorum compliance — res judicata and prior judgments — authority to represent applicants — attorney-and-client costs for mala fides.
13 April 2021
March 2021
Eviction, demolition and impoundment without a court order violate ESTA and occupier's family-life rights.
Extension of Security of Tenure Act (ESTA) – unlawful eviction – deprivation of use of land – requirement of court order for eviction and demolition. ESTA s6(2)(d) – occupier’s right to family life – includes family members (including adult children) living with occupier – just and equitable balancing with owner’s rights. Impoundment of livestock – removal and impoundment without court order unlawful where stock belong to occupier or graze in allocated camp; section 7 not applicable in circumstances. Remedies – declaratory relief, restoration of ploughing fields and grazing camps, rebuilding demolished house, return of cattle, interdict against harassment, right to return to homestead. Evidence – credibility assessments, probative value of attorney letters and eyewitness testimony.
25 March 2021
Whether occupiers’ grazing rights may be reduced without a court order and leave to appeal that decision.
Land law – Occupiers' grazing rights – Whether reduction of grazing without court order is lawful – Leave to appeal and condonation – Distinction from Mthethwa v Bester – Appealability of costs.
17 March 2021
February 2021
Eviction under s10(1)(c) requires specific, individualised proof of fundamental breach; blanket allegations insufficient.
Land Claims/ESTA — eviction under s10(1)(c) — requirement of individualised proof of fundamental breach; res judicata — identity of parties; commissioning of affidavits — curable procedural defects; justice and equity in mass eviction proceedings.
18 February 2021
Court granted condonation, found CPA had a prima facie defence, rescinded wider ex parte order and issued a narrower interim interdiction.
Rescission and condonation — late rescission application — reasonable explanation and bona fides where lay applicants relied on Department officials; Interim/inter partes relief — ex parte rule nisi rescinded and replaced by narrower interim interdiction against CPA members; Land restitution — lessees’ leases lapsed; prima facie defence to review of award of farms.
15 February 2021