S v Motlhabane and Others (86/08) [2008] ZANWHC 39 (30 October 2008)

S v Motlhabane and Others (86/08) [2008] ZANWHC 39 (30 October 2008)

The court held that the presiding officer's bona fide recusal did not constitute an irregularity amounting to a failure of justice. The discretion exercised by the presiding officer was respected, and the court aligned itself with the principle that a judge's bona fide recusal should not be easily overturned, even...

Source-derived case information.

Citation
[2008] ZANWHC 39
Parties
Applicant: The State; Respondent: Kagiso Gilbert Motlhabane; Respondent: Shimene Johannes Moeng; Respondent: Japhta Motlhabane; Respondent: Obakeng Donald Motlhabane
Court
North West High Court, Mafikeng
Jurisdiction
South Africa
Case Number
86/08
Procedural Posture
Review Application / Review Judgment Following Recusal of Presiding Officer
Outcome
The matter is referred back to start de novo before another presiding officer.
Judges
A M Kgoele, R D Hendricks
Legal Topics
Recusal of Judicial Officer, Functus Officio, Trial De Novo
Criminal Law Civil Procedure Recusal of Judicial Officer Functus Officio Trial De Novo

Source-derived case record

Summary, issues, holding and outcome

More case intelligence is available

Unlock the full research layer for this judgment.

Downloadable case file Legal principles 2 Authorities cited 1 Party arguments 2
Sign in to unlock

Parties

The State

Applicant

Kagiso Gilbert Motlhabane

Respondent

Shimene Johannes Moeng

Respondent

Japhta Motlhabane

Respondent

Obakeng Donald Motlhabane

Respondent

Procedural Posture

Review Application / Review Judgment Following Recusal of Presiding Officer

  1. 1 Whether the presiding officer's recusal constituted an irregularity amounting to a failure of justice.
  2. 2 Whether the matter should proceed de novo before another presiding officer after recusal.
  3. 3 Whether agreements between prosecution and defence regarding use of prior evidence can be honoured post-recusal.

Ratio Decidendi

The court held that the presiding officer's bona fide recusal did not constitute an irregularity amounting to a failure of justice. The discretion exercised by the presiding officer was respected, and the court aligned itself with the principle that a judge's bona fide recusal should not be easily overturned, even if the grounds are not shared by the reviewing court. The court rejected the proposal to allow the new presiding officer to determine the case based on the record of evidence already adduced, holding that the matter must start de novo before another presiding officer. The presiding officer who recused himself is now functus officio, and the case must proceed afresh.

Court Disposition

The matter is referred back to start de novo before another presiding officer.

Orders

  • The matter is referred back to start de novo before another presiding officer.