S v Matshoba and Others (CC45/13) [2013] ZAECPEHC 63; 2015 (1) SACR 448 (ECP) (27 March 2013)
- Citation
- [2013] ZAECPEHC 63
- Status
- Judgment
- Jurisdiction
- South Africa
- Court
- Eastern Cape High Court, Port Elizabeth
- Panel
- B Hartle
- Case number
- CC45/13
More details
- Court
- Eastern Cape High Court, Port Elizabeth
- Panel
- B Hartle
- Case number
- CC45/13
On this page
Professional case brief
Research organized from the available case record
01
Holding and result
The court held that the enquiry under section 49G of the Correctional Supervision Act is not a bail hearing but a sui generis process. The focus is on the duration of detention and the interests of justice, including the accused's right to a trial without unreasonable delay and the problem of prison overcrowding. In this case, there was no unreasonable delay attributable to the State, and no change in circumstances since bail was previously denied. The seriousness of the charges and the likelihood of life imprisonment if convicted are compelling reasons for continued detention. The accused's personal circumstances and willingness to be released did not outweigh these considerations. Therefore, the continued detention of the accused pending trial is justified.
Court disposition
The accused are to remain in custody pending trial. The matter is postponed for trial to 10–21 November 2014.
Orders
- The matter is postponed for trial to 10–21 November 2014.
- All accused are to remain in custody pending trial.
- Separate orders are issued for each accused under section 49G of the Correctional Supervision Act, No. 111 of 1998, confirming continued detention.
02
Material facts
Parties
The State
Applicant Counsel: Mr CanaryCacile Matshoba
Respondent Counsel: Ms CoertzenSiyabonga Brandy
Respondent Counsel: Ms CoertzenThembinkosi Speelman
Respondent Counsel: Ms CoertzenThulani Haas
Respondent Counsel: Ms Coertzen03
Procedural history
Posture
Criminal Law Application / Section 49 G Correctional Supervision Act Remand Detention Enquiry
04
Questions and positions
Legal issues
- 01
Whether the continued detention of the accused pending trial is justified under section 49G of the Correctional Supervision Act.
- 02
Whether the enquiry requires a bail hearing or is sui generis.
- 03
Whether there has been unreasonable delay in prosecution warranting release.
Party arguments
- Applicant
- The State, represented by Mr Canary, argued that the accused face serious charges involving violence and, if convicted on count 2, may face life imprisonment. This is a compelling reason against their release. The postponement of the trial was due to unforeseen systemic reasons and not attributable to the State. There has been no unreasonable delay in prosecution.
- Respondent
- Ms Coertzen, for the accused, submitted affidavits outlining their personal circumstances and willingness to be released on bail. However, she conceded there had been no unreasonable delay in the trial and no change in circumstances since bail was previously denied. The accused did not strongly contest the necessity of continued detention pending trial.
05
Court’s reasoning
Legal principles
- 01
S v Sheyi (unreported judgment, Bhisho High Court, CC4/2011, 6 August 2013)
The enquiry under section 49G of the Correctional Supervision Act is not a bail hearing but a sui generis process focused on the lapse of time and interests of justice.
- 02
Correctional Supervision Act, No. 111 of 1998
Normal principles and requirements relating to bail may overlap but do not bind the presiding officer in a section 49G enquiry.
- 03
Criminal Procedure Act, No. 51 of 1977
Unreasonable delay in prosecution may justify release, but must be established under section 342A of the Criminal Procedure Act.
06
Ratio, limits and disposition
Ratio decidendi
The court held that the enquiry under section 49G of the Correctional Supervision Act is not a bail hearing but a sui generis process. The focus is on the duration of detention and the interests of justice, including the accused's right to a trial without unreasonable delay and the problem of prison overcrowding. In this case, there was no unreasonable delay attributable to the State, and no change in circumstances since bail was previously denied. The seriousness of the charges and the likelihood of life imprisonment if convicted are compelling reasons for continued detention. The accused's personal circumstances and willingness to be released did not outweigh these considerations. Therefore, the continued detention of the accused pending trial is justified.
Obiter and limits
- The Protocol cannot bind the presiding officer regarding the interpretation that the reconsideration hearing should take the form of a bail enquiry.
- The enquiry is generally concerned with any factor impacting the interests of justice, which must be weighed against the interests of the remand detainee.
- Neither the accused nor the State were responsible for the postponement of the trial; systemic reasons caused the delay.
Court disposition
The accused are to remain in custody pending trial. The matter is postponed for trial to 10–21 November 2014.
- The matter is postponed for trial to 10–21 November 2014.
- All accused are to remain in custody pending trial.
- Separate orders are issued for each accused under section 49G of the Correctional Supervision Act, No. 111 of 1998, confirming continued detention.
Source and reliance status
Eastern Cape High Court, Port Elizabeth
This page organises the available record for research. Confirm quotations, current status, and subsequent treatment against the official source before relying on the case.
Judgment reading view
Judgment text
The complete available source text.
Eastern Cape High Court, Port Elizabeth
Judgment
IN
THE HIGH COURT OF SOUTH AFRICA
EASTERN CAPE DIVISION, PORT ELIZABETH
CASE NO: CC45/13
In the matter between:
THE
STATE
v
CACILE
MATSHOBA
SIYABONGA
BRANDY
THEMBINKOSI
SPEELMAN
THULANI
HAAS
JUDGMENT
1. The four accused appeared before me for an enquiry pursuant to the provisions of section 49G of the Correctional Supervision Act, No. 111 of 1998 (“CSA”)
2. Each of them were arrested on 23 June 2012 and have been “remand detainees” within the meaning envisaged by that term in the CSA at St Alban’s, Medium A, Correctional Centre since 26 June 2012.
3. The recently enacted provisions of section 49G of the CSA obliges the head of the remand detention facility or correctional centre, as the case may be, to refer to “the court concerned” in the manner set out in the section all remand detainees whose period of detention exceeds two years from the detainee’s initial date of admission into of the facility or centre, in order “to determine the further detention of such (detainee) or (his) release under conditions appropriate to the case”.
4. Although the accused have not yet served two years awaiting trial in terms of article 4.3 of the Justice, Crime Prevention and Security (“JCPS”) Protocol on the procedure to be followed in applying the provisions of the section 49G of the CSA (being the directives envisaged by section 49G(5)), the head of the correctional centre is expected to forward to the clerk of the court his request for the court to consider the further detention of awaiting trial prisoners once the period of detention exceeds 21 months from the initial date of admission already and it is on this basis that the head of the Correctional Centre, St Alban’s Medium A, has requested this court to consider the further detention or release of the accused as may be appropriate to the circumstances.
5. The Protocol provides that in considering the further detention of the remand detainee, the “normal principles and requirements relating to bail”, as set out in the CPA apply, but no basis for the consideration is set out in the enabling provision. Subsection 5 defers to the directives (which purpose is served by the Protocol) but only in regard to the procedures to be followed by the relevant role players whenever it is necessary to bring the proposed application.
6. In S v Sheyi, an unreported judgment of the Bhisho High Court in case number CC4/2011, which I delivered on 6 August 2013 shortly after the implementation date of the provisions of section 49G, I had occasion to interpret the provisions of the section. I held that it was neither the object nor the effect of the then newly proclaimed amendment that the court reconsidering the continued incarceration of the awaiting trial prison was required to hold a bail hearing proper such as is envisaged by section 60 of the CPA. On the contrary I opined as follows:
‘In my view all that is required is to take note that the detained person has passed a certain threshold, one which puts him into a category of persons the Department of Correctional Services should be particularly mindful of. This no doubt acts as a bulwark (and as an oversight function) against the rights of an incarcerated person being infringed without lawful cause or him being subjected to arbitrary detention. It ensures that upon reflection there remains good reason for his continued incarceration. Whilst I have no doubt that considerations such as an inordinate delay in prosecution, the loss or absence of vital evidence or witnesses (or other convincing grounds such as will evolve in practice which threaten to condemn an incarcerated detainee to an open ended and unreasonably protracted incarceration) may provide a sound reason for a court to release an accused who has hitherto been detained pending a trial, I am not persuaded that the amendment requires the court to revisit the issue as if it were a bail hearing.’
7. Although my judgment was written before the Protocol was agreed upon, I remain of the view that I am not required to hold a bail hearing. Neither in my opinion can the Protocol bind a presiding officer in any event concerning the interpretation referred to therein that the reconsideration hearing should take the form of a bail enquiry and that normal bail principles are to be applied in the process. Whilst there may be an overlap with the usual factors which are required to be taken into account in bail
determinations, the enquiry in this instance is in my view sui generis. The focus is on the lapse of time which may erode an accused’s person’s right to have his trial begin and conclude without unreasonable delay as well as the prison’s
unique problem of overcrowding in prison. The enquiry is also generally concerned with any factor which will have an impact on the interests of justice as this critical consideration must always be kept in mind when weighed against the interests of a remand detainee.
8. Ms Coertzen on behalf of the accused prepared affidavits for each accused which merely set out their personal circumstances. Whilst they each suggest a willingness to be released on bail, none of the accused strongly contend that there are valid reasons why their continued incarceration pending the trial, which is to be heard on 10 – 21 November 2014, should not be ordered. Each of the accused previously unsuccessfully applied for bail in the Magistrate’s Court before and it was not suggested in the case of any one of them that there have been any change of circumstances concerning them which would have entitled them to approach the court which declined them bail in the first instance (no doubt because their release was considered likely to prejudice the ends of justice) on the basis of new facts.
9. Ms Coertzen further conceded on behalf of all of the accused that there had not been an unreasonable delay in the trial, certainly not on the basis envisaged in section 342A of the Criminal Procedure Act, No. 51 of 1977, warranting an investigation by this court into the circumstances or an interference with the pace of the prosecution.
10. It appeared to be accepted that the postponement of the trial this week, which I might add is the first appearance in this court, was not due to the fault of the state. On the contrary it is common cause that it is the result of “unforeseen systemic reasons” due to the fourth roll being cancelled. Whilst I accept that neither are any of the accused responsible for the delay, this is not a factor which per se operates to exclude their further incarceration pending the trial which will be heard in the next eight months.
11. In advancing reasons in support of the continued detention of the accused, Mr Canary, who appeared for the State, correctly pointed to the fact that the accused face serious charges involving violence and that, if they are convicted on count 2, may face life imprisonment. This in itself is a serious factor militating against the release of any of them on bail pending their trial.
12. Whilst I have taken into account all the considerations placed before me there does not appear to me to be any good reason why the accused should not remain in custody pending their trial.
13. In the result the matter is postponed for trial to the agreed date : 10 – 21 November 2014, with all the accused to remain in custody pending the trial. Separate orders will issue in respect of each accused in terms of section 49G of the Correctional Supervision Act, No. 111 of 1998 that their continued detention is so ordered.
_____
B
HARTLE
JUDGE
OF THE HIGH COURT
HEARD: 26 MARCH 2014
DATE OF JUDGMENT : 27 March 2013
Appearances:
For the state : Mr Canary, Director of Public Prosecutions, Port Elizabeth.
For the accused : Ms Coertzen, Legal Aid Board, Port Elizabeth.
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