Bulawayo High Court - 2004 December

27 judgments
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27 judgments
Citation
Judgment date
December 2004
A magistrate may not impose fines exceeding section 271(2)(a) limits when conducting guilty-plea summary trials; use s271(2)(b) for non-minor offences.
Criminal procedure — summary guilty-plea procedure s271(2)(a) v s271(2)(b) — competence of fines — substitution of sentence on review — factors guiding use of s271(2)(a).
29 December 2004
Eviction application dismissed: not urgent and improperly brought by motion where verbal lease raised disputed facts.
Eviction — urgency — requirements for urgent chamber applications; Eviction procedure — action vs motion where verbal lease and disputes of fact exist; Interim relief identical to final relief — impermissible and defeats respondent's right to be heard
15 December 2004
An innocent third-party purchaser with valid transfer is entitled to eviction of a former occupier who failed to challenge prior ejectment or the sale.
Sale and transfer of immovable property — innocent third-party purchaser — transfer in good faith — prior ejectment order — obedience to court orders — eviction authorised — costs on attorney-and-client scale
15 December 2004
Unexplained delay and self-created urgency defeated the applicant's urgent application; it was dismissed with costs.
Civil procedure — Urgent applications — Test for urgency; delay and need for explanation; self-created urgency; monetary loss remediable by damages insufficient.
15 December 2004
Urgent relief dismissed: no demonstrated urgency for interdict against letting or collecting rentals; substantive contractual issues deferred.
Civil procedure – urgent chamber application – urgency must be established; certificate of urgency requires application of mind; loss of rentals not necessarily irreparable; contractual dispute over option price escalation and applicability of in duplum rule left undecided.
15 December 2004
Bail pending appeal refused where sentence likely only reduced and risk of abscondment would hinder administration of justice.
Bail pending appeal – governing factors: prospects of success and risk of abscondment – likely reduction of custodial sentence insufficient to justify bail – grant refused to prevent hindrance of administration of justice.
15 December 2004
Conviction for unlawful export upheld; sentence and forfeiture set aside for failure to inquire into mandatory "special reasons."
Exchange Control Act – unlawful export of goods without Reserve Bank authority – mandatory minimum sentence under s5(4) – obligation to inquire into "special reasons" – forfeiture under s7 – requirement to afford accused opportunity to make submissions.
15 December 2004
Reduction of charges and delay did not justify bail; risk of abscondment and witness interference remained.
Bail pending trial – changed circumstances – reduction of charges and delay – whether reduction likely to produce non-custodial sentence – onus on applicant to prove attendance – risk of abscondment and witness interference.
15 December 2004
Magistrate misapplied s271(2)(a), exceeded sentencing jurisdiction and failed to hear mitigation; convictions confirmed, sentences amended.
Criminal procedure – sentencing procedure under s271(2)(a) vs s271(2)(b) – jurisdictional limit on fines – misapplication of summary procedure – duty to hear mitigation before sentence.
15 December 2004
Applicants succeed on procedural default after respondent’s counsel failed to attend opposed hearing; substantive issues not decided.
Procedural law – counsel’s duty to attend hearings – absence without lawful excuse – procedural default – declaratory relief – fines paid under duress – costs awarded.
15 December 2004
Section 89(6) gives the Labour Court exclusive first-instance jurisdiction; the High Court dismissed the application for lack of jurisdiction.
Labour law — Jurisdiction — Section 89(6) Labour Relations Act grants exclusive first-instance jurisdiction to the Labour Court; Labour Court has review powers under section 89(2)(a)(iii) — disciplinary proceedings — applicability of employer's Code of Conduct to managerial employees (not decided)
8 December 2004
Court refused postponement for alleged ill-health, entered judgment for plaintiffs, and awarded punitive costs for defendants' delaying conduct.
Civil procedure — postponement — illness — fitness to attend court — abuse of process by deliberate delay — punitive costs; declaration of necessary witnesses and allocation of witness-report costs
8 December 2004
Applicant failed to show exceptional circumstances warranting leave to sue curator or preferential payment of frozen bank deposits.
Banking Act s53–54 — curatorship — stay of proceedings and leave to sue — consideration of merits in leave application — leave refused where no strong arguable case or exceptional circumstances; depositor risk and insolvency; court will not order piecemeal payment while curator conducts holistic assessment
8 December 2004
Applicant failed to prove entitlement to an interlocutory interdict freezing the respondent's mining assets and funds.
Interdict pendente lite; requirements — prima facie right, injury or apprehended infringement, absence of alternative remedy, balance of convenience; material disputes of fact on affidavits; misrepresentation in founding affidavit; nominee signatory to joint account as alternative remedy
8 December 2004
Short, reasonable delay with tendered wasted costs can justify removal of a bar for late opposition.
Civil procedure – Default/bar for failure to file opposing papers – Order 12 Rule 83(b) discretion to allow appearance – Rule 84(2) oral application for removal of bar – Good cause required – Tender of wasted costs to address prejudice.
8 December 2004
The applicant's unreasonable delay defeated urgency; the urgent application was dismissed with costs.
Civil procedure — Urgent applications — delay and inaction by applicant — applicant as author of urgency — urgency not established where applicant unreasonably delays; Judicial management — writ of execution against entity under judicial management; Registration of labour tribunal determination.
8 December 2004
Appellate court upheld refusal to allocate retiree's lump sum for child maintenance, finding no misexercise of discretion.
Maintenance law – application for portion of retiree's lump-sum terminal benefits – discretion of Maintenance Court – post-retirement employment and ability to pay – appellate review of discretionary factual findings.
8 December 2004
Ambiguous award of matrimonial assets resolved; applicant given movable property and 35% of house proceeds.
Family law – division of matrimonial property – clarity of orders concerning movable property – repossession to defeat claim – recognition of indirect/intangible contributions – just and equitable share of matrimonial home (35%).
8 December 2004
Appellate court remitted matter for retrial where trial court failed to make credibility findings and assess probabilities.
Civil procedure – appeal – inadequacy of trial judgment – failure to make credibility findings and analyse probabilities – impossibility of effective appellate review – remittal for trial de novo before a different magistrate.
8 December 2004
Rape conviction on one count confirmed; other reduced to attempted rape due to insufficient proof of penetration.
Criminal law – Rape – requirement to prove penetration – attempted rape where penetration not established – credibility of child complainant – use of circumstantial and medical evidence to infer penetration – sentence substitution.
8 December 2004
Convictions confirmed; indecent‑assault sentence against a 15‑year‑old held manifestly too lenient and uncertified by the court.
Criminal law — Indecent assault against a juvenile — Sentencing — Whether sentence is unduly lenient — Review power — Court declines to certify a nine‑month term; suggests 3–5 years effective imprisonment.
8 December 2004
Unsworn, unchallenged victim allegations of prior misconduct are prejudicial at sentencing and must be given under oath and open to challenge.
Criminal law — Sentencing — Admission of victim’s unsworn allegations about prior unprosecuted misconduct as aggravation — Right to cross‑examine and requirement for such evidence to be given under oath; sentencing misdirection and substitution on review; consideration of community service.
8 December 2004
A wholly suspended 12-month sentence with community service for theft of a bull was unduly lenient; certificate withheld.
Criminal law – Stock theft – Sentence – Whether a wholly suspended sentence incorporating community service is unduly lenient for theft of one head of cattle – Established guidance recommends not less than three years' imprisonment absent special mitigation – Recovery of property may be fortuitous and not mitigating.
8 December 2004
Provisional order to seize a vehicle discharged where respondents’ uncontradicted affidavit undermined the interdict and urgency.
Civil procedure — Urgent provisional/interim relief — Ex parte order sought to be confirmed — Opposing affidavit alleging valid sale and transfer of motor vehicle — Failure of applicant to file answering affidavit — Uncontradicted material facts undermining interdict — Self-induced or non-established urgency — Provisional order discharged with costs.
8 December 2004
Agreements to change ownership without a statutory subdivision permit are void; lower courts must follow Supreme Court precedent.
Town and planning law – Regional Town and Country Planning Act s39(1)/s40 – agreements for change of ownership or consolidation without statutory permit void – X‑Trend‑A‑House binding precedent – stare decisis – relief for specific performance/compelled transfer inappropriate where statute prohibits the agreement
1 December 2004
Applicant entitled to specific performance after matching an offer and respondents' mala fide conduct frustrated the sale.
Property law – right of first refusal – matching competing offer – entitlement to specific performance; Vendors/executors – mala fide conduct in sale process; Specific performance preferable where enforceable and damages inadequate; Costs – attorney-and-client scale for dishonest conduct; Minor misdescription of party condoned.
1 December 2004
A court may not impose two separate sentences for one offence; suspension must be of part or whole of a single sentence.
Criminal procedure — Suspension of sentence — Section 358(2) Criminal Procedure and Evidence Act — Sentence for an offence is single and may be wholly or partly suspended — Court may not impose two separate sentences for one offence — Community service as condition of suspension.
1 December 2004