High Court of South Africa Western Cape, Cape Town - 2024

258 judgments

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258 judgments
Citation
Judgment date
December 2024
Reported
Provisional winding up of a solvent close corporation granted where mutual trust between members irretrievably broke down.
Close corporation — just and equitable winding up of solvent company — section 67 CC Act read with section 81(1)(d)(iii) Companies Act; partnership‑like private company — loss of mutual trust and confidence; interlocutory strike‑out of affidavit material — scandalous/vexatious/hearsay/new matter principles; admission of late affidavit in interests of justice (Rule 6(5)(e)); Kalil prima facie test for provisional winding up.
30 December 2024
Reported
Sole director held personally liable under s 424 for reckless trading; debt fixed at R4,035,000 plus interest, reduced by any liquidation dividend.
* Companies Act s 424(1) – Reckless trading – Director personally liable where company incurs debts with no reasonable prospect of payment; objective/subjective test from Philotex applied. * Novation/waiver – settlement agreement and subsequent court order may extinguish or supersede prior contractual entitlements (capital-growth v. mora interest). * Section 424 discretion – causation between reckless conduct and claimed debt relevant to fairness of personal liability; reduction for dividends in liquidation.
18 December 2024
Bail was denied as applicant failed to prove it was in the interest of justice post-conviction.
Criminal law – Bail pending appeal – Evidential burden on applicant – Interest of justice post-conviction – Abscondment risk.
17 December 2024
Applicant introduced purchaser during mandate and was held the effective cause entitled to commission.
Estate agency — joint mandate interpretation — effective cause (causa causans) of sale — purchaser introduction during mandate — whether affidavit proceedings appropriate or referral to trial required (Wightman) — indemnity given by third party — costs on Scale B.
13 December 2024
Owner entitled to evict unlawful occupier school, but eviction structured to protect learners and ensure placements by education authorities.
* Property law – actio rei vindicatio and eviction – unlawful occupation of property by an independent school. * Procedural law – PIE protections for occupiers and requirement for notices and hearings for persons resident by, through or under an occupier. * Constitutional law – balancing property rights with learners’ constitutional right to basic education and children’s best interests; horizontal application of socio-economic rights. * Administrative/education law – duties of provincial education authority to place learners and practical requirements for relocation. * Costs – award of attorney-and-client costs and potential de bonis propriis liability for individual representative.
13 December 2024
Altered OEM price list constituted material misrepresentation; ruling upheld, but five‑year sanction set aside as irrational due to material factual error.
• Administrative law — review of procurement decisions — interpretation of tenders: text, context and purpose govern interpretation; bidders must strictly comply with tender pricing requirements. • Procurement law — misrepresentation in bids — submission of altered OEM price lists and undisclosed incorrect discounts can be material and render a bid non-responsive. • Sanctions/blacklisting — sanction decisions must be rationally connected to correct facts; a material factual error can taint and invalidate a sanction. • Consequences — setting aside an unlawful sanction may require setting aside related contract terminations and refusals to conclude contracts.
13 December 2024
High Court lacked jurisdiction over tax assessment dispute absent s105 direction; no exceptional circumstances and PAJA time‑bar exceeded.
Tax law – jurisdiction – s 105 Tax Administration Act – Tax Court is default forum for disputes about assessments/decisions – exceptional circumstances required to permit High Court review; PAJA s 7(1) – reasonableness and 180‑day time‑bar; ETI claims – section 9(4) and forfeiture; substitutionary relief rarely appropriate where verification/audit required.
13 December 2024
Eviction granted: respondents unlawful occupiers; claimed pre-emptive rights unenforced; postponements for representation refused.
* PIE – eviction of unlawful occupiers – court must balance rights of occupier and owner and determine just and equitable relief. * Possession/rei vindicatio – registered owner entitled to possession absent enforceable right against owner. * Pre-emptive/right of first refusal – personal contractual right against prior owner does not necessarily bind innocent purchaser; no enforcement steps taken. * Postponement and legal representation – right to representation not absolute; non-indigent litigant’s delay and lack of frank disclosure do not justify further postponement. * Costs – costs including wasted costs may be awarded where conduct causes unnecessary delays.
13 December 2024
Appellant charged with Schedule 6 offences failed to prove exceptional circumstances; magistrate properly refused bail.
Bail appeal — section 65(4) CPA — interference only if lower court wrong; Schedule 6 offences — section 60(11) onus to show exceptional circumstances; section 60(4) grounds (evade trial, endanger public, influence witnesses); weight of investigative evidence (CCTV, firearms, police pursuit); medical and community‑tie arguments insufficient without convincing evidence.
12 December 2024
Reported
Player’s intentional punch in school water polo was unlawful and negligent; school not liable absent notice of prior risk.
Delict — assault during contact sport — negligence and wrongfulness of intentional punch exceeding sporting risk; private defence pleaded and rejected; school’s vicarious/primary liability assessed — no breach where no notice of prior dangerous propensities and proper refereeing/disciplinary systems in place; costs apportionment for unnecessary defence evidence.
12 December 2024
Bail cancellation upheld due to reoffending and absconding risk; deficient plea agreement referred to DPP for investigation.
Criminal procedure – Bail cancellation under s 68(1) CPA – Reoffending on bail and risk of absconding justify withdrawal; Plea and sentence agreements – s 105A compliance – prosecutor must consider triad (personal circumstances, nature of offence, previous convictions) and NDPP directives; omission of material particulars (previous convictions, quantity/value of seized goods) renders agreement deficient and may constitute dereliction of duty; Referral to DPP for investigation where prosecutorial conduct appears improper; Courts must ensure s 105A agreements contain sufficient particulars so sentence can be assessed as 'just.'
12 December 2024
Court varied prior order under Rule 42: removed executors, ordered new appointment, compelled full accounting, and imposed de bonis propriis costs.
* Civil procedure – Rule 42 variation – correction of ambiguity/error in prior order to reflect court’s intention. * Executors – removal of executors and appointment of new executor by the Master. * Administration of estates – obligation of former executors to deliver detailed, documented account to successor. * Costs – costs de bonis propriis ordered, jointly and severally, on attorney-and-client scale.
11 December 2024
Undisputed microdot evidence establishing vehicle identity defeated the applicant’s claim; leave to appeal refused for lack of prospects.
* Evidence – microdot identification of motor vehicles – microdots as immutable unique identifiers and persuasive proof of VIN/chassis identity. * Civil procedure – motion proceedings – applicant bound by respondent’s version unless demonstrably untenable; need to plead and prove factual basis for new grounds. * Administrative action/procedural fairness – duty to plead and establish factual basis for procedural-fairness complaint. * Appeal – leave to appeal requires reasonable prospect of success under s 17(1)(a) of the Superior Courts Act.
11 December 2024
Applicants’ bid to refer disputed loan-account charges to oral evidence was dismissed; sale and transfer remain valid.
* Civil procedure – motion proceedings – referral to oral evidence – applicants must establish case in founding papers; new factual allegations in reply ordinarily struck out; court exercises discretion under Rule 6(5)(g). * Mortgage enforcement – sale in execution – correctness of statement of account – coding of charges (HMP/HOC) and res judicata where incorporated in earlier order. * Execution procedure – sheriff’s authority and notice requirements under Rule 46; sheriff’s returns and hearsay. * Municipal law – section 118 Municipal Systems Act – rates clearance certificate is for municipality’s benefit; failure to obtain does not automatically void transfer; applicants’ standing limited.
10 December 2024
Applicant’s defamation claim failed for lack of proof linking the website publication to the applicant; application struck out with costs.
Defamation — identification requirement where publication is not by name; necessity to prove link or association to applicant; evidentiary particularity and corroboration of distinctive features; declaratory and interdictory relief unavailable absent identification; costs — senior counsel on scale C recoverable.
9 December 2024
Reported
Legislative acts are sovereign and not 'commercial transactions', so the respondent retains foreign‑state immunity.
Foreign-state immunity – Foreign States Immunities Act – commercial-transaction exception (s 4) – meaning of 'commercial transaction' – sovereign or governmental acts (legislation and implementation) are excluded – exception to jurisdiction must be clearly established on pleadings – exception upheld where particulars do not disclose a commercial cause of action.
9 December 2024
Respondent misappropriated trust funds and failed to comply with investigative requests; court struck him from the roll of attorneys.
Legal profession – trust funds – misappropriation of client trust monies; failure to comply with investigative request under rule 40.2.4; misrepresentation to regulator and court; fitness to practise – striking off vs suspension; High Court jurisdiction under common law and s 44 LPA to order striking off.
6 December 2024
Respondent struck off for fabrication of trust accounts, misappropriation of trust funds and breaches of LPC Rules.
Legal Profession — Trust accounts — Fabrication of ledgers and reconciliations; large-scale ‘round’ transfers from trust to business accounts; trust deficits and misappropriation — Breach of LPC Rules (record-keeping, reconciliation, separation of trust/business funds, withdrawals) — Failure to establish court-ordered trusts — Fitness to practice — Striking off and appointment of curator; costs.
4 December 2024
Reported
Municipal installation of a sewer over private land without notice or consultation was unlawful; declaration suspended for remedial period.
* Property and servitudes – subdivision condition granting municipality rights to convey sewers – exercise of servitude-like rights must be civiliter modo (respectful, reasonable, consultative). * Administrative law – municipal action installing infrastructure on private land can attract procedural fairness obligations (notice and consultation); PAJA-relevant principles reinforce common-law duties. * Expropriation – no formal expropriation where servitude-like condition applied; Expropriation Act not engaged. * Applications procedure – inspection in loco generally inappropriate in motion proceedings as it may produce real evidence and subvert motion-rule fact assessment. * Remedies – declaration of unlawfulness may be suspended to avoid public-health/utility harm; court may direct removal after remediation period.
3 December 2024
Reported
Whether board meetings held without the constitutionally required KCI‑UK spiritual leaders were void and prior orders could override the constitution.
Voluntary associations – Constitutions as contracts – Mandatory qualification clauses for board composition – Clause requiring at least two KCI‑UK spiritual leaders binding; an improperly constituted board must first fill qualifying vacancies (clause 8.4) before acting – Prior court orders do not displace constitutionally required board qualifications – Meetings and constitutional amendments adopted by an improperly constituted group are void.
2 December 2024
Urgent interdict against council set aside: municipality lacked standing, interim relief unjustified, applicant ordered to pay costs personally.
Municipal law — capacity to litigate — municipality v council; Urgent relief — reconsideration under Rule 6(12)(c); Interim interdict — requirements (prima facie right, irreparable harm, balance of convenience); Separation of powers — limits on judicial interference with municipal council’s s58 powers (OUTA); Abuse of process — inadequate service, non-disclosure and delay; Costs — personal liability and attorney-and-client scale.
2 December 2024
November 2024
An occupier’s refusal to provide housing information and waiver of municipal assistance can justify eviction under PIE.
* PIE – eviction – s 4(7) and 4(8) – court’s duty to inquire into occupiers’ circumstances and to consider City report when occupier faces homelessness. * Occupier conduct – refusal to complete municipal housing questionnaire or to accept municipal assistance may justify proceeding without fuller City report. * Civil procedure – refusal of further postponement for legal representation not necessarily a miscarriage of justice where occupier’s conduct causes delay.
29 November 2024
A restraint of trade barring ex-employees from working was largely rejected; only solicitation of former clients was interdicted.
Labour law – Restraint of trade – Protectable interest – Reasonableness – Employee solicitation of clients – Hairdressing industry – Evidence of confidential information or solicitation required.
28 November 2024
Reported
Rescission for alleged fraud refused for inordinate delay and failure to prove fraud; provisional sequestration granted.
Rescission — common law rescission for alleged fraud — high threshold to prove fraud in motion proceedings — inordinate delay/timeousness — exercise of discretion to refuse rescission — res judicata/abuse of process — provisional sequestration after nulla bona returns.
28 November 2024
Master’s refusal to grant a special liquidator’s fee was rational; review dismissed and costs awarded to the Master.
Companies law – Liquidators’ remuneration – section 384(1)-(3) Companies Act – Master’s discretion under s384(2) to increase or decrease remuneration – review under s151 Insolvency Act (statutory review/de novo powers) – PAJA and principle of legality – locus standi of liquidators to sue in representative capacity – relevance of time sheets, joint duty of liquidators, creditor protection and prevention of abuse.
28 November 2024
Master’s refusal to increase liquidators’ special fee at first account upheld; review dismissed and costs awarded.
Companies Act s384(1)-(2) – liquidators’ remuneration – scope for departure from tariff; Insolvency Act s151 statutory review powers; locus standi of liquidators to challenge remuneration; Master’s supervisory duty to protect creditors; rationality and relevance of considerations in fee assessments.
28 November 2024
Plaintiff awarded R1 million general damages (defendant liable for R800,000) for serious permanent leg injuries; Scale C costs.
* Road Accident Fund – assessment of general damages for serious orthopaedic injuries under s17(1)/(1A). * Quantum – evaluation of pain, suffering, disfigurement, permanent disability and loss of amenities; use of comparable awards as guideline. * Liability conceded in part (80%) – effect on payable sum. * Costs – party-and-party costs including expert fees; Rule 67A(3) discretion applied to award counsel’s fees on Scale C for work after 12 April 2024. * Interest – calculated from 14 days after judgment to date of final payment.
28 November 2024
The execution creditor failed to prove a partnership; second claimant succeeds to most attached goods; third claimant’s car deferred.
Interpleader (Uniform Rule 58) – onus depends on possession at time of seizure; admissibility—s 65 record inadmissible without s 3(1)(c) application; proof required to establish partnership/universal partnership to defeat claimant’s title; capacity—appointment of curator ad litem required before adjudicating assets of an incapable third party; costs—successful claimant not necessarily entitled to costs where credibility concerns exist.
28 November 2024
Former spouse entitled to terminate co-ownership via actio communi dividundo and obtain equal net proceeds on sale.
* Property law – actio communi dividundo – availability where extrinsic relationship has ceased – free v bound co-ownership. * Civil procedure – motion proceedings – Plascon-Evans rule and bona fide disputes of fact requiring action. * Family/property – treatment of non-financial and indirect contributions when dividing marital property acquired during marriage. * Remedies – sale by private treaty and equal division of net proceeds; receiver not appointed when unnecessary and expensive. * Costs – successful applicant awarded costs, including counsel.
27 November 2024
Applicants perempted challenge and orders holding settlement terms as judgment on breach were valid and enforceable.
* Civil procedure – settlement agreements made orders of court – effect and enforceability – clause making settlement order operate as judgment on breach. * Peremption – acquiescence in settlement orders precluding rescission. * Settlement content – inclusion of related debts (ISA, additional funding, fees) permissible where connected to lis. * Interpretation – orders to be read to give practical effect; not rendered ambiguous by preservation of original causes of action. * Variation/rescission – inherent power and Rule 42(1)(b) inapplicable where provisions are substantive and res judicata.
26 November 2024
Executor removed where beneficiary-executor refused to account, conflicted over estate business proceeds, and delayed administration.
Wills – interpretation of testamentary provisions concerning an on-going business; doctrine of election; Plascon-Evans approach to disputed factual allegations; fiduciary duties of executors; removal of executor for conflict of interest, delay and failure to account; duties to lodge liquidation and distribution account and to hand over estate records.
26 November 2024
A restraint of trade preventing a former hairstylist from working locally was unreasonable absent a protectable interest or client solicitation.
Labour law – Restraint of trade – Reasonableness and enforceability – Requirement of a protectable proprietary interest – Skills and customer relationships in hairdressing industry – Absence of confidential information and client solicitation – Public policy considerations.
26 November 2024
The plaintiff's particulars sufficiently disclosed causes of action; the defendants' exceptions were dismissed with costs.
• Civil procedure – exception for failure to disclose cause of action – excipient must show that on every construction no cause of action is disclosed; pleaded facts accepted as true. • Contract/delict – consequential damages (lost rental) – foreseeability and causation may be sufficiently pleaded by alleging the parties contemplated loss from delay; exact quantum need not be foreseen at contracting. • Joinder and attribution – pleading that a contracting party acted as authorised representative may suffice to implicate associated corporate entities. • Remedy – defective particulars ordinarily addressed by amendment; exceptions should not be used to improperly dismiss a cause of action.
25 November 2024
Applicants failed to show prospects for an urgent anti-dissipation interdict; leave to appeal dismissed with costs.
Civil procedure – urgent interim interdict and anti-dissipatory relief – requirements for prima facie right, absence of alternative remedy, imminent irreparable harm and balance of convenience; representation of corporate party by non-lawyer – challenge not raised in founding papers; obligation to request reasons under rule 49(1)(c) – absence of written reasons not fatal where reasons not formally sought; late-filed answering affidavit and election to proceed – applicant cannot thereafter complain.
25 November 2024
Respondent held in contempt for bringing proceedings after being declared a vexatious litigant; suspended committal and costs ordered.
Vexatious litigant — instituting proceedings without leave contrary to s 2(1)(b) of the Vexatious Proceedings Act; contempt of court — civil and criminal aspects; limits on access to court; role of informer in contempt proceedings; competency to impose suspended committal or fine where punitive relief not specifically prayed for.
22 November 2024
A vexatious-litigant order barring instituting proceedings without leave justified striking a business rescue application and awarding punitive costs.
Business rescue – Companies Act s131; vexatious litigant order – prohibition on instituting proceedings without leave; separate legal personality cannot be used to circumvent a personal prohibition; irregular step – striking application from the roll; costs awarded on attorney-and-client scale.
21 November 2024
Further‑and‑better discovery application dismissed as overbroad and speculative; plaintiff’s discovery affidavit upheld.
Civil procedure – Rule 35(3)/(7) – further and better discovery – requirements of specificity, identification and relevance; discovery affidavit ordinarily conclusive absent reasonable grounds or mala fides; overbroad and vague discovery requests as fishing expedition and abuse of process; privacy limits to discovery; NCA/PSIRA factual relevance considered.
21 November 2024
Court interdicted use of AFRULA for marula liqueur, finding statutory infringement and dilution of well‑known AMARULA trade marks.
Trade marks – statutory infringement – s34(1)(a): likelihood of deception or confusion between AFRULA and well‑known AMARULA; Trade marks – s34(1)(c): protection of well‑known marks against taking unfair advantage/dilution; Passing‑off – requires market presence and actual or probable damage; Constitutional freedom of expression limited where commercial trade‑mark rights are infringed; Interim and final interdictory relief and costs awarded.
21 November 2024
Reported
A usufructuary’s express right to dispose of estate assets and reinvest proceeds is enforceable; executor approval may not be unreasonably withheld.
• Succession and wills – interpretation: give full effect to dominant clause but honour express special bequest limiting ownership until usufructuary’s death; • Usufruct – scope: "full usufruct" permitting disposal of assets and reinvestment of proceeds; • Executors’ approval: approval of reinvestment must not be unreasonably withheld and must aim to preserve capital while prioritising usufructuary's comfort; • Enforcement: court may compel heirs to sign transfer documents and authorise Sheriff to sign.
20 November 2024
Reported
Payments made by a company after the commencement of winding‑up are void dispositions and must be repaid; Savers Lane was the company in liquidation.
Companies Act s 341(2) – dispositions after commencement of winding‑up are void; trading name forms part of company identity; Pride Milling – court’s limited discretion to validate applies only to dispositions made between lodgement of winding‑up application and grant of provisional order; payments made after provisional order cannot be validated; preference/ordinary course analysis relevant.
19 November 2024
Court orders unpaid capital judgment with interest limited by in duplum; surety bound after cession and settlement.
Civil procedure – authority to institute proceedings; suretyship – cession and succession in title – effect on surety’s liability; contractual interest – in duplum rule limits recoverable interest to unpaid capital; evidentiary weight of certificate of balance and need for updated, pleaded calculations.
19 November 2024
Reported
Interim interdict refused where bidder submitted non‑responsive tender and public interest in timely housing outweighed speculative harm.
Administrative law – tender review – interim interdict – Setlogelo/Webster test – prima facie right, irreparable harm, balance of convenience; non-responsiveness (failure to meet tender specifications) fatal to bid; exhaustion of internal remedies (s 62 Systems Act); separation of powers and public interest in timely housing delivery; costs and counsel’s fees (Rules 67A, 69).
19 November 2024
Condonation granted for late filing of plea; exploration of mandate legality raised complex issues.
Condonation for late filing – Requirements for uplifting a bar under Uniform Rule 27 – Bona fide defense – Legality of mandate agreement.
19 November 2024
An exception that no cause of action is disclosed was dismissed; pleadings disclose a statutory Companies Act claim against a former director.
Companies Act — director’s statutory liability to company for contraventions of duties (ss 75, 76, 77) — exception test — whether particulars disclose cause of action — distinction from condictio furtiva/theft claims; pleadings to be read as whole; request for particulars available.
18 November 2024
Application to reinstate a lapsed appeal refused for unexplained delay, attorney negligence, and no prospects of success.
Civil procedure – reinstatement of lapsed appeal – condonation for failure to prosecute – factors: extent and cause of delay, prejudice, prospects of success – attorney negligence – appellate reluctance to disturb credibility and factual findings supported by expert evidence.
18 November 2024
Unauthorised initiation of litigation leads to dismissal and personal cost order; respondents' improper conduct limits full costs.
Sectional Titles – two-unit body corporate – authority to litigate – defective trustee resolutions – requirement of two trustee signatures for levy clearance – conveyancer effecting transfer despite invalid clearance – unauthorised litigant sued for costs – unclean hands / par delictum in costs exercise; bank’s security prejudiced if transfer cancelled.
18 November 2024
An FSP cannot contractually preclude statutory debarment; a s14(3) notice is preparatory (not PAJA administrative action) but reviewable for legality.
Financial services regulation – FAIS Act s14 debarment process – distinction between initiation (s14(3) notice) and final debarment (s14(1)) – initiation not administrative action under PAJA but exercise of public power reviewable under legality – FSP cannot lawfully agree not to commence debarment where duty exists – ulterior purpose ground requires clear proof.
15 November 2024
A post‑commencement transfer from a company account is void under s 341(2); repayment with interest and costs ordered.
Companies Act s 341(2) — dispositions after commencement of winding‑up void; banker–customer relationship/commixtio — funds in company account deemed company property; no bank agreement or earmarking — exception inapplicable; transfer by third party’s representative does not negate disposition; court may refuse validation to protect concursus creditorum.
14 November 2024
Defaulting third defendant held liable for defamatory media publications; plaintiffs awarded general and special damages, interest and attorney‑and‑client costs.
Defamation — publication to media and social platforms; presumption of wrongfulness once publication proven; defendant bears onus to rebut; damages in defamation compensatory and generally modest; proof of special damages by accounting records; procedural default and refusal to uplift bar — court declines further postponement; costs on attorney‑and‑client scale appropriate for abusive or dilatory conduct.
13 November 2024
Leave to appeal refused: clause construed as enforceable restraint, rectification in reply allowed, s18 relief granted; costs for respondent.
Employment law – restraint of trade – interpretation of written restraint clause – reading in omitted word to give clause operation; Rectification – permissible in replying affidavit where answering affidavit shows party did not previously dispute written record; Section 18 Superior Courts Act – exceptional circumstances and irreparable harm established where employee solicits employer’s clients; Costs – party and party costs including counsel on scale B awarded.
12 November 2024