High Court of South Africa Western Cape, Cape Town - 2023 May

27 judgments

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27 judgments
Citation
Judgment date
May 2023
Reported
Simultaneous delivery of a replication and a summary judgment application is not inherently an irregular step under Rule 32/Rule 30.
Civil procedure – Rule 32 – summary judgment – whether plaintiff may deliver replication simultaneously with summary judgment application; Rule 30 – setting aside alleged irregular step – requirement of no further step taken with knowledge of irregularity and proof of prejudice; waiver – substantive, fact‑specific inquiry.
29 May 2023
Applicant subject to vexatious-litigator restraint must obtain leave before proceeding; matter struck from the roll with wasted costs.
Vexatious litigant – Vexatious Proceedings Act restraint – requirement to obtain leave before instituting proceedings; effect of Superior Courts Act s18(1) and appeal refusal; striking application from roll; wasted costs (including costs of two counsel).
29 May 2023
Settlement disposing of assets of a liquidated company was void; auction proceeds must be paid to the liquidators.
Companies law – winding-up – final winding-up order establishes concursus creditorium; s341(2) Companies Act 61/1973 – dispositions after commencement of winding up void ab initio; landlord’s tacit hypothec – cannot be perfected to prefer creditor post winding-up; contract interpretation – Endumeni applied; onus on claimant to prove ownership of movables sold at auction.
26 May 2023
Court granted interim interdict protecting applicants’ possession and use of an access road pending final action; respondents’ counter-claim dismissed.
* Property dispute – access road and boundary – mandament van spolie and interim interdicts – requirements: prima facie right, well-grounded apprehension of irreparable harm, balance of convenience, no alternative remedy. * Procedural point – attempted late change from final to interim relief; Rule 28 and prejudice to respondent considered but merits interrogated. * Evidentiary approach – Plascon-Evans test for final relief; interlocutory relief decided on applicants’ version where respondents fail to raise decisive doubt.
26 May 2023
Warning statements recorded in English after real‑time translation lacked probative value; accused acquitted for insufficient proof.
Criminal law – evidence – admissibility and probative value of warning statements – language issue where isiXhosa speakers’ statements were recorded in English after real‑time translation – statements admissible but unreliable; insufficient evidence to convict. Constitutional law – language rights (s 6) and fair trial rights (s 35) implicated by statement-taking practices.
26 May 2023
Gross receipts constitute a juristic person’s "turnover" for NCA thresholds; applicant need not register and may enforce notarial bonds.
* National Credit Act – registration of credit providers – juristic person threshold – definition of "turnover" as total monies received (gross receipts) into business account; * Effect of non-registration – unlawful/unenforceable agreements; * Notarial covering and collateral bonds – enforcement against movable property; * Rule nisi granted ex parte confirmed; * Costs – attorney-and-client and interlocutory costs in the cause.
25 May 2023
Acting magistrate’s hostile social media campaigning created reasonable apprehension of bias; proceedings set aside and remitted for rehearing.
Judicial impartiality — reasonable apprehension of bias arising from social media activity; recusal obligations of judicial officers; Code of Judicial Conduct for Magistrates and Bangalore Principles; review under Superior Courts Act s 22(1)(b),(c); proceedings rendered null by failure to recuse; remittal for rehearing before a different magistrate.
24 May 2023
Short‑term commercial letting and event use of a Single Residential 1 dwelling is unlawful without municipal consent.
* Municipal and planning law – land use schemes – Saldanha Bay Municipal Integrated Zoning Scheme By‑Law – primary uses versus consent uses; tourism and holiday housing require municipal consent. * Zoning – Residential Zone 1 – 'dwelling house'/'dwelling unit' construed as residential living accommodation for one household; commercial short‑term letting and events not permitted without consent. * Ancillary use principle – uses not expressly provided for in scheme are not permitted where scheme provides specific consent categories (Rustenburg jurisprudence). * Neighbour enforcement – neighbouring owners may obtain interdicts for zoning contraventions; proof of imminent harm and lack of alternative remedy sufficient.
24 May 2023
Reported
A defective charge sheet did not invalidate conviction where the accused’s plea admissions established culpable homicide and no prejudice arose.
* Criminal procedure — defective charge sheet — statutory offence (s61(1) NRT Act) vs. common-law culpable homicide — insufficiency of factual averments. * Section 112(2) plea — admissions curing defects where accused intended and admitted elements of substituted offence. * CPA ss 86, 88 — amendment before judgment; review remedy where amendment post-conviction not possible. * Review (s304A) — substitution/confirmation of conviction on review where no prejudice to accused and evidence supports offence.
24 May 2023
Lease validly terminated on two months’ notice; matter remitted to determine whether eviction is just and equitable.
Property law – lease termination – clause permitting termination on two months’ written notice – termination effective on communication; Eviction procedure – organ of state may proceed under s 4 PIE; PIE’s just-and-equitable enquiry (s 6(3)) applies where residential occupation involved; Waiver – lapse of time and negotiations do not establish waiver absent unequivocal evidence; Remittal – where initial court fails to consider just and equitable factors, matter to be remitted for that enquiry.
22 May 2023
Summary judgment can be granted on penalty claims where the defendant fails to substantiate a bona fide s3 defence.
Summary judgment; Conventional Penalties Act s3; onus on debtor to prove disproportionality; bona fide defence requirement in summary judgment; qualification of Premier Finance on penalty claims.
22 May 2023
Reported
Applicants for bail on Schedule 6 charges must prove exceptional circumstances; evidence of witness interference and weak affidavits justified continued detention.
Criminal procedure – bail in Schedule 6 cases – onus on accused under s60(11)(a) to prove exceptional circumstances – witness intimidation and interference – relevance and limits of affidavit alibi evidence – detention conditions ordinarily not exceptional.
22 May 2023
An unqualified pre-trial concession admitting accident-related psychiatric injury prevents belated denial of causation; limited repudiation of certain expert findings allowed.
• Civil procedure – amendment of plea – withdrawal of prior admissions and compromises; limits on reopening pre-trial concessions. • Evidence – expert agreements and joint minutes – when parties may repudiate expert opinions. • Delict – causation of psychiatric injury – effect of pre-trial admissions and settlement on proof of causation. • Case management – effect of late amendments on fairness and prejudice.
18 May 2023
Applicant proved debt and respondent failed to show a bona fide dispute; provisional winding-up ordered.
Company law – Liquidation – Urgent provisional winding-up where creditor proves claim prima facie and company fails to show bona fide dispute on reasonable grounds (Badenhorst rule); oral agreement to forgive debt must be clearly proved; prospective liabilities (debt becoming due on transfer) relevant to inability-to-pay inquiry; discretion to refuse winding-up narrowly applied.
17 May 2023
Court declares that a judicial grant of "care" under the Children’s Act includes "custody" and "legal custody" for medical‑scheme dependency purposes.
* Children’s Act – interpretation of "care" and "custody" – section 1(1), section 1(2) and section 18(2). * Medical schemes – Rule requiring "legal custody" for dependent status – interaction with Children’s Act definitions. * Guardianship and placement orders – effect of court order placing children "in care" for third-party administrative purposes. * Urgent ex parte relief to prevent prejudice to a dependent child's medical and educational needs.
17 May 2023
Applicant social‑housing landlord entitled to evict long‑term non‑paying occupiers where leases validly cancelled and City offered emergency housing.
PIE – eviction of unlawful occupiers from social housing – locus standi of social housing institution as person in charge – validity of lease cancellation for non‑payment – applicability of Consumer Protection Act notice period and inapplicability of Rental Housing Act s5(5) to termination for breach – just and equitable enquiry – City’s duty to provide temporary emergency accommodation.
16 May 2023
Reported
Court ordered production of electronic client lists and Mauritius-related documents and directed Rule 35 discovery under exceptional circumstances.
Rule 35 discovery – electronic records as documents – shareholders' "book"/client lists discoverable; Rule 30A compulsion for non-compliance with Rule 35(12); Rule 35(13) exceptional circumstances to order discovery in motion proceedings; production of foreign-company documents where affidavit refers to them; confidentiality undertakings and costs order.
15 May 2023
Accused charged with Schedule 6 offences failed to establish exceptional circumstances to justify bail under section 60(11).
Bail – Schedule 6 offences – section 60(11)(a) CPA – onus on accused to prove exceptional circumstances; strength of State’s prima facie case; personal circumstances and unstable residence insufficient; conditions of detention generally not “exceptional circumstances”; public interest and safety considerations relevant.
15 May 2023
Reported
Pleadings failed to disclose a cause of action: tacit exclusive-occupation term inconsistent with express maintenance clause and instalments payable in advance precluded withholding.
Exception—failure to disclose cause of action; Contract interpretation—tacit term v express terms; Maintenance clauses—Trust’s right to effect repairs and recover costs; Reciprocity and exceptio non adimpleti contractus—payment in advance excludes withholding instalments; Pleadings—requirement to plead facts enabling computation of remission.
15 May 2023
Accused charged with Schedule 6 offences failed to show exceptional circumstances for bail and was refused.
Criminal procedure – Bail – Section 60(11) CPA – Schedule 6 offences – accused must adduce evidence of exceptional circumstances; burden to show exceptional circumstances and interests of justice; assessment of personal circumstances versus apparent strength of State case; prior convictions and propensity to offend while on bail relevant to risk to administration of justice and public confidence.
11 May 2023
Court ordered mutual discovery: defendant must properly comply with plaintiff’s Rule 35(3) notice; plaintiff must produce specified documents and a Rule 21 particular.
Civil procedure — discovery — Uniform Rules 35(3), 35(6) and 35(7) — adequacy of response: inspection offer or sworn statement of non-possession and whereabouts required; discovery wide in scope and may include documents relevant to merits though also touching quantum. Civil procedure — further particulars (Rule 21) — court will order particulars only if strictly necessary to avoid prejudice or embarrassment in trial preparation; requests for evidence or fishing expeditions refused; particulars relating to discovered documents may be compelled.
8 May 2023
Applicant lacked standing and failed to prove clear right or reasonable apprehension; overbroad, vague interdict dismissed with costs.
Administrative law/Police powers – interdict – locus standi to sue for unnamed third parties; Non-joinder – failure to join persons with direct and substantial interest; Civil procedure – clarity of court orders – overbroad/vague relief unenforceable (Eke v Parsons); Final interdict requisites – clear right, injury or reasonable apprehension, no alternative remedy; Criminal Procedure Act – execution of arrest warrants and powers to enter premises (ss 43, 48).
8 May 2023
Reported
Late review of municipal tender dismissed for undue delay; procurement and fraud attacks also fail on the merits.
Administrative law – review under PAJA – condonation of delay – s 7(1)/s 9 extension – interests of justice. Procurement law – tender evaluation – 80/20 price/preference application; effect of invalid 2017 PPPFA regulations on municipal SCMP. Evidence – hearsay and unsubstantiated allegations of fraud insufficient to set aside award. Procedure – quorum and composition of bid committees. Remedies – substitution inappropriate; compensation not established. Costs – punitive attorney-and-client costs warranted for abusive, scatter‑shot review.
5 May 2023
Application for protective interdict against police dismissed as moot and on merits; arrests and seizures found lawful.
Interdictory relief — requirements for final interdict (clear right, injury, absence of alternative remedy); Mootness doctrine — no live controversy where applicant later arrested and charged; Arrests and seizures — lawfulness where effected pursuant to warrant or with consent; Firearms Control Act considerations and safekeeping; Plascon-Evans rule — disputes of fact and inadmissible hearsay; Costs following event, including costs of two counsel.
4 May 2023
Applicant’s under‑settlement claim barred by prior direct‑claim settlement and statutory prescription.
* Road Accident Fund Act – section 23 – prescription of RAF claims – five‑year protection for lodged claims; prescription runs from date cause of action arose. * Direct claims – acceptance and payment – full and final settlement of past loss of earnings; effect on subsequent under‑settlement claims. * Knowledge for prescription – when plaintiff/attorney became aware of prior settlement (30 June 2014) determines commencement of prescription. * Failure to disclose by claimant and failure to respond by claimant’s attorney – fatal to later claim for under‑settlement. * RAF statutory limitations – no condonation/waiver of prescription under RAF Act.
4 May 2023
Court orders demolition of an encroaching boundary wall; developer non-joinder, estoppel and compensation defenses rejected.
* Property law – encroachment – mandatory interdict to remove encroaching boundary wall; * Non-joinder – developer not a necessary party where relief affects current registered owners’ real rights; * Estoppel – no basis where representation, reliance and prejudice not pleaded or established; * Successors-in-title – liabilities from predecessor-in-title attach to current registered owner; * Administrative remedies – exhaustion not required where municipality has confirmed encroachment and declined to act; * Remedy – demolition is primary remedy; compensation inadequate where it would not permit intended building works; * Costs – attorney-and-client costs warranted for vexatious/obstructive conduct.
2 May 2023
Applicant failed to prove wilful contempt or section 97 NCA intent to frustrate; application dismissed with costs.
Contempt of court – wilful disobedience and mala fides required; section 97(5) NCA – offence requires proven intent to mislead or frustrate credit provider; evidentiary burden shifts after order and non‑compliance established; disputes of fact on affidavit rejected only if demonstrably untenable (Fakie test).
2 May 2023