High Court of South Africa Western Cape, Cape Town - 2013

64 judgments

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64 judgments
Citation
Judgment date
December 2013
Circumstantial evidence can establish the applicant’s knowledge that funds were proceeds of unlawful activity; conviction confirmed, sentence reduced.
* Criminal law – Money laundering (POCA s 4) – evidential proof of proceeds: State may prove specific unlawful source or rely on circumstances to infer criminal origin and accused's knowledge. * Circumstantial evidence – credibility and mendacity – irresistible inference supporting conviction. * Sentencing – principle of consistency – appellate reduction of sentence to align with co‑accused’s role and punishment.
19 December 2013
Applicant’s unregistered secondary trade mark SOPHIA protected against respondent’s use due to likelihood of passing off.
Passing off – unregistered secondary trade mark (fancy name) – distinctiveness/reputation acquired by SOPHIA through CWG auction exposure – likelihood of confusion/deception (aural and market contexts) – intention not necessary; likelihood suffices – final interdict and costs including senior counsel awarded.
19 December 2013
Reported
Applicant fleeing public‑order disturbances qualified for refugee status; Appeal Board improperly constituted and decisions set aside.
* Administrative law – Refugee appeal board – composition and quorum – statutory requirement that Appeal Board sit with chairperson and at least two other members and at least one legally qualified member – decision taken by single member invalid. * Refugee law – proper application of s 3(b) (events seriously disturbing or disrupting public order) distinct from s 3(a) (persecution) – RSDO and RAB misapplied legal standard. * Procedural fairness – disclosure of adverse reports and opportunity to respond – RSDO/RAB failed to afford fair hearing and adequate reasons. * Review remedies – substitution justified in exceptional circumstances where remittal would be unjust or body appears biased.
11 December 2013
November 2013
Reported
A High Court may enforce its maintenance orders by writ despite Maintenance Act enforcement procedures in the maintenance court.
* Maintenance law – enforcement – Whether Chapter 5 of the Maintenance Act precludes enforcement of High Court maintenance orders by writ of execution from the High Court; * Statutory interpretation – interaction between Maintenance Act and Superior Courts Act; * Election of remedies – whether an emoluments attachment order precludes subsequent High Court enforcement; * Civil enforcement – moratorium and enquiry procedures under Maintenance Act vs High Court execution.
20 November 2013
Reported
Whether a municipal speaker’s finding and suspension of councillors’ voting rights was ultra vires and unlawful.
Local government — internal council procedure — Speaker’s powers and limits under the Structures Act and the Code of Conduct; principle of legality; locus standi of provincial MEC to litigate in respect of council governance; intergovernmental dispute framework not engaged; unlawfulness and ultra vires suspension/revocation of councillors’ voting rights; limits on court-ordered compulsion of MEC investigatory action.
12 November 2013
Reported
Master’s authorisation of a s417/418 enquiry was reviewable and set aside after fraudulent non‑disclosure and procedural unfairness.
Companies Act s417–418 enquiry — Master’s authorisation — procedural fairness and PAJA applicability; fraudulent non-disclosure by opposing attorney vitiating administrative action; legality principle — fairness, rationality, transparency; review and setting aside of authorisation.
11 November 2013
Reported
Inability to annex a lost written contract does not extinguish a cause of action; secondary evidence and condonation are available.
Civil procedure – Rule 18(6) – written contracts – failure to annex contract because original destroyed or lost – secondary evidence admissible; Rule 27(3) condonation available – Rules procedural not substantive – Moosa distinguished.
6 November 2013
Non-compliance with Rule 46(3) will not invalidate a sale where the applicant had knowledge of the attachment and suffered no prejudice.
* Civil procedure – Execution against immovable property – Rule 46(3) – Service on owner, occupier and Registrar of Deeds – Non-compliance does not automatically vitiate sale; inquiry focuses on whether breach defeats rule’s purpose and causes prejudice (Todd v FirstRand Bank applied). * Evidence – Actual knowledge of attachment and prior conduct (payments to stop sales) relevant to prejudice inquiry.
5 November 2013
Summary judgment refused where scope of power of attorney and attorney-in-fact’s capacity raised triable issues.
Summary judgment — Uniform Rule 32(2) verification by corporate deponent; domicilium clauses and jurisdiction; incomplete annexure to simple summons; scope of general power of attorney; capacity of attorney-in-fact to bind principal; bona fide triable defences precluding summary judgment.
4 November 2013
October 2013
Reported
Applicants succeeded: municipal approvals set aside; reliance on elderly affidavit for ground-level height determination prohibited.
Administrative law – judicial review of municipal planning decisions – NBRA s7 approval and LUPO departures – functus officio and irrationality – procedural fairness (audi alteram partem) – admissibility and weight of land surveyor certificates and historical affidavits in determining "natural ground level" – delay rule in pre-PAJA review proceedings.
30 October 2013
Separation under Rule 33(4) refused; onus on due diligence to be addressed provisionally at trial under Rule 39(11).
Admiralty/insurance — application for separation of issues under Rule 33(4) — MSA warranty and Inchmaree proviso — tactical denials in pleadings permissible — overlapping evidence defeats separate hearing — incidence of onus on want of due diligence is res nova and should be provisionally addressed at trial under Rule 39(11).
30 October 2013
Reported
Claimant failed to prove patrimonial loss where future earnings depended on continued tax evasion and business prospects were uncertain.
Road Accident Fund — loss of earning capacity — requirement to prove patrimonial loss on balance of probabilities — public policy bars awarding damages for future earnings dependent on continued unlawful conduct (tax evasion) — risk of prosecution and imprisonment as contingency — evidential sufficiency regarding foreign tax law and likelihood/timing of prosecution; reliability of actuarial models vs fair lump-sum award.
23 October 2013
Reported
Administrative reinstatement under s 82(4) restores corporate personality and property retrospectively; validation of acts requires s 83(4) relief.
• Arbitration — s 31(1) Arbitration Act — court’s inquiry limited to whether award can properly be made an order; illegality not apparent on award must be pleaded in arbitration or set aside under s 33. • Companies Act 2008 — ss 82 and 83 — effect of administrative reinstatement under s 82(4): retrospective restoration of corporate personality and property, but not automatic validation of corporate acts. • Companies Act 2008 — s 83(4) — court may, on application by an interested person, make just and equitable orders (including validation of acts during deregistration) after dissolution/reinstatement. • Companies Act 1973 s 38(1) — distinction between direct object of financial assistance and ultimate goal; transaction held not to contravene s 38(1).
22 October 2013
Reported
7 October 2013
September 2013
A regulator and its delegated association held liable for failing to prevent illegal commercial tandem paragliding, causing the applicant’s injuries.
Aviation law – paragliding – status of tandem flights for reward – carrier’s (air service) licence requirement – AIC 18.23 and proposed Parts 24/94/96 – ultra vires exemption; Administrative delegation – CAA, Aero Club, SAHPA – continuing statutory accountability; Delict – omissions by public authorities and statutory bodies – duty of care, wrongfulness and causation; Volenti non fit iniuria – not available to statutory bodies where activity proscribed by statute and applicant unaware of illegality.
20 September 2013
Appellate court substituted a disproportionate custodial sentence after finding the magistrate’s demeaning conduct and misdirected sentencing.
* Criminal law – Sentencing – Disproportionate custodial sentence set aside where court failed to properly weigh plea, remorse, restitution, illness and primary caregiver status. * Judicial conduct – Demeaning, sarcastic remarks by magistrate undermine duty to uphold dignity and fair sentencing in constitutional democracy. * Sentencing principle – Proper application of S v M: special regard to children’s interests without permitting undue avoidance of appropriate punishment. * Appeal – Substitution of sentence with suspended imprisonment; referral to Magistrate’s Commission.
20 September 2013
Application for repayment of alleged overpaid maintenance dismissed; payments found not unjustified and no duress or excusable mistake.
Family law – maintenance – claim for repayment of alleged overpayments – condictio indebiti – excusability of mistake – duress – enrichment where payments applied to minor children’s maintenance – parol evidence and variation of consent maintenance order – public policy and best interests of the child.
11 September 2013
Reported
Amended s 35(3) requires sworn evidence and limits non‑suspension to circumstances relating to the offence.
National Road Traffic Act s 35(3) — amended requirement of sworn evidence before non‑suspension order; 'circumstances relating to the offence' restricts matters courts may consider — excludes unrelated personal circumstances; appellate review of trial court’s exercise of s 35(3); prosecutions’ duty to test s 35(3) evidence.
10 September 2013
Court ordered disclosure of foreign arbitration documents relevant to causation and limitation despite asserted arbitration confidentiality.
Arbitration — confidentiality — no absolute implied duty absent agreement; exceptions where disclosure is consented, court-ordered, reasonably necessary to protect legitimate interests, or required by interests of justice; discovery under Uniform Rule 35(3)/(7) — relevance test; Merchant Shipping Act s261 limitation plea — related foreign arbitration documents may be discoverable when relevant to causation and limitation issues.
5 September 2013
August 2013
Reported
Filing a business rescue application with the Registrar suspends pending winding‑up under section 131(6) of the Companies Act.
Companies Act — Business rescue v liquidation — s 131(6) suspension of liquidation pending adjudication; meaning of "made" — filing/lodging with Registrar constitutes making; s 133 moratorium applies once business rescue proceedings commenced; purposive interpretation to avoid absurdity; creditors as affected persons may enforce time limits; possible personal liability for director/member for wasted costs; referral of attorneys' conduct to Law Society.
23 August 2013
The court held that dual jurisdiction for insolvent company winding-up applications remains under the Old Act pending new legislation.
Company law – Winding-up – Jurisdiction – Old Companies Act 61 of 1973, s 12 – New Companies Act 71 of 2008, Schedule 5 Item 9 – Dual jurisdiction for liquidation (registered office or principal place of business) remains applicable for insolvent companies pending alternative legislation – Decision in Sibakhulu Construction not followed to extent inconsistent.
23 August 2013
Reported
Mandatory placement of child offenders on the sex-offender register without a hearing is unconstitutional; courts must have discretion and hear representations.
* Sexual Offences Act s 50(2) — National Register for Sexual Offenders — mandatory inclusion of convicted persons' particulars — application to child offenders. * Child Justice Act — rehabilitative and best-interests principles — potential conflict with peremptory register inclusion. * Constitutional rights — dignity, privacy, fair hearing (s 34), freedom of trade — limitation analysis under s 36. * Audi alteram partem — obligation to afford accused opportunity to make representations before register order. * Remedy — declaration of invalidity; suspended order; reading-in to afford discretion and a right to be heard; referral to Constitutional Court.
21 August 2013
14 August 2013
Reported
An applicant must identify the right alleged; replacing a via simpliciter route with an adequate alternative is not spoliation.
* Mandament van spolie – requirement to identify the nature of the right alleged to be dispossessed; quasi-possession vs physical possession. * Servitudes – via simpliciter; servient tenement may alter route provided alternative is adequate and non-prejudicial. * Replacement of an existing route by an adequate alternative over the same servient land is not spoliation. * Admission of subsequent events as fresh evidence on appeal requires very special circumstances and was refused.
8 August 2013
Reported
An ambiguous email did not constitute the applicant's contractual demand, and enforcing acceleration would breach public policy.
Contract – loan agreement – clause requiring written demand to trigger default; meaning of “demand”; acceleration clause – whether trivial unpaid mora interest can trigger full acceleration; public policy and constitutional values (good faith/ubuntu) in contract interpretation; enforcement of cession in securitatem debiti (not reached).
5 August 2013
Reported
Ineffective pre-trial legal assistance leading to an incriminating statement required exclusion and acquittal; other appellants’ sentences upheld.
* Criminal procedure – admissibility of statement – right to legal representation – ineffective assistance where counsel fails to prevent client’s self-incriminating statement. * Constitutional right against self-incrimination – compelled or unprotected admissions – exclusion of statement where counsel’s basic duties not performed. * Sentencing – minimum-sentence provisions (s 51(1) v s 51(2) of Act 105/1997) – indictment specification and fair-trial implications – appellate confirmation of sentence where substantive rights unimpaired.
5 August 2013
July 2013
School‑closure decisions under s33 are administrative action governed by PAJA; only one closure set aside for procedural unfairness.
* Administrative law – school closure decisions under s33 Schools Act constitute administrative action subject to PAJA. * Constitutional law – s33(2) not unconstitutional; ministerial discretion constrained by constitutional rights. * Procedural fairness – adequacy of initial reasons and requirement to give gist of case depends on context; material new reasons not previously disclosed vitiate process. * Review grounds – irrationality/arbitrariness and material error of fact assessed with caution in polycentric, policy‑laden decisions.
31 July 2013
June 2013
Reported
26 June 2013
Reported
Whether substantial and compelling circumstances justify deviation from statutory minimums for rape, murder and aggravated robbery — none found.
Sentencing — triad approach — application of section 51(1) Criminal Law Amendment Act and Schedule 2 — rape and murder attracting life imprisonment — substantial and compelling circumstances threshold — robbery with aggravating circumstances prescribed minimum — concurrency and effective sentence — declaration unfit to possess firearm.
14 June 2013
Reported
Accused convicted of rape, murder, robbery and attempted murder based on DNA, similar‑fact evidence and admitted hearsay.
* Criminal law – circumstantial and similar‑fact evidence – cumulative assessment to infer identity and intent. * Forensic DNA – semen on panty and vaginal swab mixtures as identification and to infer penetration. * Hearsay – anonymous informant admissible under s 3(1)(c) Law of Evidence Amendment Act when corroborated and in interests of justice. * Identification – dock and contemporaneous identification evaluated with caution and corroboration. * Procedure – section 212(12) affidavit evidence of absent pathologist permitted with interrogations.
11 June 2013
Reported
Representative purchaser lacked standing; sale agreement void and unrectifiable for failing Alienation of Land Act formalities.
Contract/Property — Sale of land — Identity of parties and signatures required by s 2(1) Alienation of Land Act — Agreement void for vagueness where purchaser described only as future 'shelf company' — Representative who signed on behalf of purchaser lacks personal locus standi — Invalid formal document incapable of rectification.
6 June 2013
May 2013
Anton Piller order set aside for lack of prima facie contract, no real risk of destruction, and abuse of ex parte procedure.
Anton Piller orders — requisites: prima facie cause of action, specified vital documents, real and well‑founded risk of destruction — ex parte relief and urgency — abuse of process — Plascon‑Evans approach to disputed facts — costs on attorney and client scale.
29 May 2013
Reported
Failure to inform an unrepresented accused of appeal/review rights invalidates the conviction and sentence.
* Criminal procedure – automatic review (s 304 CPA) – reviewing court may intervene where omission to inform accused of review/appeal rights leads to potential miscarriage of justice. * Constitutional right to fair trial – duty to inform unrepresented accused of right to appeal/review. * Remedy – setting aside conviction and sentence and refund of fines paid.
21 May 2013
Delegate’s withdrawal of permanent residence upheld where evidence supported inference that bona fide spousal relationship ceased within three years.
Immigration law – withdrawal of permanent residence – section 26(b)(ii) lapse where "good faith spousal relationship" ceases within three years – Regulation 33 definition and investigative powers – standard of review under PAJA and Constitution – inferential reasoning and credibility in administrative decisions.
8 May 2013
Reported
Rule 35 discovery notices cannot be used to delay summary judgment; summary judgment proper where no bona fide defence is shown.
* Civil procedure – Summary judgment (Rule 32) – purpose and procedure – defendant cannot defer summary judgment by invoking discovery notices under Rule 35(12) or (14). * Civil procedure – Discovery (Rule 35) – pre-trial documents for pleading – not a substitute for requirements to oppose summary judgment. * Summary judgment – requirements for plaintiff’s verifying affidavit and for defendant to show bona fide defence or furnish security. * Security and special execution – enforcement against surety and declaration of property specially executable.
3 May 2013
April 2013
Reported
Cessionary cannot appropriate life-policy proceeds before secured debt is due; executor may protect cedent’s reversionary interest.
Cession in securitatem debiti – analogous to pledge – cessionary’s right to receive but not necessarily appropriate proceeds; cedent’s reversionary interest vests in estate on death; duty of cessionary to act as bonus paterfamilias; executor entitled to protect reversionary interest and to challenge insurer’s reduced payment.
30 April 2013
30 April 2013
Failure to register for VAT or to submit returns does not automatically amount to criminal fraud absent a duty to disclose and intent to defraud.
Criminal law – fraud – elements: misrepresentation and intention to defraud – silence/non-disclosure may amount to fraud only where a legal duty to disclose exists; VAT law – statutory offences for failure to register and failure to submit VAT returns; mens rea for theft where VAT is deemed included; sentencing – appellate interference where trial court’s discretion is vitiated or sentence is disturbingly inappropriate.
30 April 2013
Reported
A 100% shareholder with use and an expectancy to acquire a vessel has a sufficient insurable interest to claim the insured value.
* Admiralty/Marine insurance – interpretation of policy and Institute Fishing Vessel Clauses – ‘loss’ as physical loss of vessel. * Insurable interest – flexible South African approach to distinguish insurance from wagering. * Shareholder’s interest – 100% shareholder may have insurable interest in company asset sufficient to claim insured value. * Valued policy – entitlement to insured sum on total loss without proving patrimonial diminution.
29 April 2013
Mandatory mediation/arbitration under reg 2(5) applies to s 46 interim‑contract disputes, not s 41 negotiated‑contract negotiations; application dismissed.
• Administrative law / transport law – Construction of National Land Transport Act: distinction between s 41 negotiated contracts and s 46 existing/interim contract amendments.• Regulation 2(5) read restrictively – mandatory mediation/arbitration under regs 6–9 applies to s 46 disputes, not to s 41 negotiation processes.• Interim contracts assigned to provinces make the province the relevant contracting authority under s 46(2).• Municipal s 41 negotiating duty requires good faith and reasonableness but does not impose a duty to agree or permit compulsory mediation/arbitration.
26 April 2013
Reported
Court upheld special plea: prospective matrimonial loss claims on breach of promise are not a valid contractual cause of action.
* Family law – breach of promise to marry – validity of contractual action for breach of promise – whether recovery of prospective matrimonial losses permissible in light of constitutional values and changing mores. * Common law development – s 39(2) Constitution – duty to reassess actions that no longer reflect boni mores and public policy. * Precedent – Van Jaarsveld v Bridges: persuasive obiter dicta; not binding where ratio based on factual findings.
24 April 2013
Extrinsic evidence can cure a s6 defect: a suretyship signed before a final loan agreement was held valid and enforceable.
Suretyships – s6 General Law Amendment Act 50 of 1956 – requirement that terms be embodied in writing – incorporation by reference – admissibility of extrinsic evidence to identify principal debt – principal obligation may be future – Plascon-Evans test for disputes of fact.
24 April 2013
Court held s83(4) enables judicial revival of administratively deregistered entities, restoring assets and voiding execution sale.
Companies/Close corporations – Deregistration as removal from register equals dissolution – s82(3) and s83(1)–(4) Companies Act 2008 – Judicial revival under s83(4) available for administrative deregistration – Alternative remedies: s82(4) administrative reinstatement by CIPC or s83(4) court relief – Effect of voiding dissolution: assets/liabilities re-vest; acts during dissolution remain of no effect – Close corporations deregistered pre-1 May 2011 can be restored by court order under s83(4).
19 April 2013
Reported
Court may void dissolution and restore a deregistered close corporation under s83(4), re-vesting assets and liabilities.
* Corporate law — Deregistration and dissolution — application of s 83(4) of the Companies Act 71 of 2008 to administrative deregistration under s 82(3) and to close corporations via amended s 26 CC Act. * Remedies — administrative reinstatement (s 82(4)) v judicial relief (s 83(4)) — court may restore deregistered entities where compliance with administrative prerequisites is impractical. * Effect of declaration void — assets and liabilities immediately prior to dissolution re-vest; acts during dissolution generally not validated. * Execution sales — sale in execution while corporation deregistered may be void (property bona vacantia). * Regulations — prescribed requirements for administrative reinstatement are not a precondition to court-ordered restoration under s 83(4).
19 April 2013
Reported
8 April 2013
Reported
Warrantless targeted searches under the Customs Act largely unconstitutional; limited warrantless searches allowed for regulated premises with safeguards.
Customs Act — s 4(4)–(6) — warrantless entry and search — privacy right (s 14) — Magajane s36 analysis — routine (random/compliance) vs non-routine (targeted/enforcement) searches — designated premises (licensed warehouses, rebate stores, pre-entry facilities) — limits on warrantless searches — interim reading-in and 18‑month suspension of invalidity.
8 April 2013
Reported
Ex post facto Treasury approval can validate a liquidated- estate claim; lack of prior consent alone does not justify expungement.
Exchange Control Regulations (Reg 10(1)(c)) – effect of failure to obtain prior Treasury/SARB consent on contractual claims; concursus creditorum and proving claims in liquidation; ex post facto Treasury approval; review under s151 of the Insolvency Act; expungement under s45.
5 April 2013
March 2013
Reported
Transfers under a settlement can be realisable property and affected gifts under POCA and thus be restrained.
POCA – Chapter 5 restraint – affected gift – settlement/compromise cannot shield proceeds of crime; mortgage bonds and cash payments are realisable property; innocent recipients not entitled to proceeds; joinder of indirect-interest shareholders unnecessary.
27 March 2013
A s129 NCA notice is a peremptory prerequisite; late compliance after adjournment does not prevent prescription.
National Credit Act – s129(1)(a) notice prerequisite to enforcement – s130(4) adjournment and compliance – effect on prescription – prospective operation of NCA requirements; premature summons does not interrupt prescription.
22 March 2013
Court interdicted closure of rural schools where public hearings and consultation were procedurally inadequate, protecting learners' right to basic education.
Administrative law – Schools Act s33 – requirement to inform governing bodies, to grant reasonable opportunity to make representations and to conduct public hearings; delegation of functions (s62) permissible; adequacy of public hearings and meaningful consultation; right to basic education (s29) and state obligations; interim interdict pending review and separation of powers.
19 March 2013