Sithole v S (A402/2018) [2019] ZAGPPHC 1060 (22 November 2019)
- Citation
- [2019] ZAGPPHC 1060
- Status
- Judgment
- Jurisdiction
- South Africa
- Court
- North Gauteng High Court, Pretoria
- Panel
- Senyatsi, Neukircher
- Case number
- A402/2018
More details
- Court
- North Gauteng High Court, Pretoria
- Panel
- Senyatsi, Neukircher
- Case number
- A402/2018
On this page
Professional case brief
Research organized from the available case record
01
Holding and result
The court found that the lower court failed to exercise its discretion judicially when declaring the appellant a habitual criminal. The lower court did not conduct an inquiry into the reasons for the appellant's repeated petty theft offences, nor did it consider the non-violent nature of the offences and the lack of danger posed to society. The respondent conceded this point. The appeal was upheld, and the declaration as a habitual criminal was set aside and replaced with a determinate sentence of imprisonment, partially suspended.
Court disposition
Appeal upheld; declaration as habitual criminal set aside and replaced with a determinate sentence.
Orders
- The appeal is upheld.
- The declaration of the appellant as a habitual criminal is replaced with the following sentence: The accused is sentenced to five years imprisonment, two of which are suspended for a period of five years on condition that the accused is not convicted of a similar offence.
02
Material facts
Parties
Albert Dumisani Sithole
Appellant Counsel: R Du PlessisThe State
Respondent Counsel: WilliamsAmounts and remedies
- Value of Stolen Sandals: ZAR 349
- Imprisonment Term Imposed: ZAR 5
03
Procedural history
Posture
Criminal Appeal / Appeal Against Sentence and Declaration as Habitual Criminal
04
Questions and positions
Legal issues
- 01
Whether the lower court exercised its discretion judicially in declaring the appellant a habitual criminal under section 286(1) of the Criminal Procedure Act.
- 02
Whether the nature and circumstances of the appellant's offences justified a declaration as a habitual criminal.
- 03
Whether the appellant's previous convictions alone were sufficient for such a declaration.
Party arguments
- Applicant
- The appellant contended that the lower court failed to conduct an inquiry into the circumstances surrounding his repeated petty theft offences. He argued that the mere existence of multiple previous convictions should not have been the sole basis for declaring him a habitual criminal, and that the offences were non-violent and did not pose a danger to society.
- Respondent
- The respondent, represented by Adv Williams, conceded that the lower court did not make an adequate inquiry into the reasons for the appellant's repeated petty theft offences and acknowledged that this omission affected the proper exercise of judicial discretion.
05
Court’s reasoning
Legal principles
- 01
Criminal Procedure Act 51 of 1977, section 286(1)
A court may declare a person a habitual criminal if satisfied that the person habitually commits offences and the community should be protected, but the decision remains a matter of judicial discretion.
- 02
S v Niemand 2001 (2) SACR 654 (CC)
Even if the court is convinced that a person habitually commits crimes and the community ought to be protected, the court still has a discretion whether to make the declaration.
- 03
R v Edwards 1953 (3) SA 168 (A)
The discretion to declare a person a habitual criminal must be exercised judicially, considering the nature and circumstances of the offences.
06
Ratio, limits and disposition
Ratio decidendi
The court found that the lower court failed to exercise its discretion judicially when declaring the appellant a habitual criminal. The lower court did not conduct an inquiry into the reasons for the appellant's repeated petty theft offences, nor did it consider the non-violent nature of the offences and the lack of danger posed to society. The respondent conceded this point. The appeal was upheld, and the declaration as a habitual criminal was set aside and replaced with a determinate sentence of imprisonment, partially suspended.
Obiter and limits
- A declaration as a habitual criminal is a severe sentence, potentially resulting in indefinite imprisonment, and must be reserved for cases where the community genuinely needs protection from the offender.
- The nature of the offences and the circumstances under which they were committed are critical factors in the exercise of judicial discretion under section 286 of the Criminal Procedure Act.
Court disposition
Appeal upheld; declaration as habitual criminal set aside and replaced with a determinate sentence.
- The appeal is upheld.
- The declaration of the appellant as a habitual criminal is replaced with the following sentence: The accused is sentenced to five years imprisonment, two of which are suspended for a period of five years on condition that the accused is not convicted of a similar offence.
Source and reliance status
North Gauteng High Court, Pretoria
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.
North Gauteng High Court, Pretoria
Judgment
REPUBLIC OF SOUTH AFRICA
IN
THE HIGH COURT OF SOUTH AFRICA
GAUTENG DIVISION, PRETORIA
(1) REPORTABLE: NO/YES
(2) OF INTEREST TO OTHER JUDGES: NO/YES
(3)
REVISED
CASE NO: A402/2018
22/11/2019
In the matter between:
ALBERT
DUMISANI SITHOLE
APPELLANT
And
THE
STATE
RESPONDENT
JUDGMENT
SENYATSI AJ
[1] This is an appeal against declaration of the Appellant as a habitual criminal in terms of section 286(1) of the Criminal Procedure Act 51 of 1977.
[2] The Appellant appeared before the Magistrate District Court of Merafong held at Oberholzer where he pleaded guilty to a count of theft of sandals valued at R349.00. He was found guilty of the offence.
[3] After the previous convictions were proved against him, the case was transferred to the Regional Court for sentencing in terms of section 114(1)(b) of the Criminal Procedure Act 51 of 1977 ("the CPA")
[4] The Appellant was sentenced in the Regional Court and declared a habitual criminal in terms of section 286(1) of the CPA. His leave to appeal was dismissed in the Regional Court and after petitioning this Court, he was granted leave on the sentence.
[5] The appellant raises, as one of the key grounds, the fact that the court a quo did not make an enquiry into the circumstances under which the string of theft cases were committed. The Appellant furthermore argues that his many previous convictions which were admitted ought not to have been the only consideration for declaring him habitual criminal.
[6] Section 286(1) of the CPA provides for a serial offender to be declared a habitual criminal. The section has been subjected to scrutiny in a number of judgments such as S v Niemand 2001 (2) SACR 654 (CC); S v Van Eck 2003 (2) SACR 563 (SCA); S v Nawaseb 1980 (1) SA 339 (SWA); S v Wayi 1994 (2) SACR €; and S v Stenge 2008 (2) SACR (C); S v Trichard 2014 (2) SACR 245 (GJ); S v Smith 2019 (1) SACR 500 (WCC).
[7] The section 286 of the CPA has the effect that once declared a habitual criminal, such person is sent to prison for an indeterminate period. The duration of sentence of a person declared a habitual criminal is determined by the Parole Board and the Commissioner of Correctional Services Department.
[8] Section 286 of the CPA provides as follows: -
"(1) Subject to the provisions of ss (2), a superior court or a regional court which convicts a person of one or more offences, may, if it is satisfied that the said person habitually commits offences and that the community should be protected against him, declare him an habitual criminal, in lieu of the imposition of any other punishment for the offence or offences of which he is convicted."
[9] Whether or not to make such a declaration is a matter of judicial discretion. (See Styetler: Constitutional Criminal Procedure: A commentary on the Constitution of the Republic of South Africa, 1996 (Butterworth) 1998 at 421-2.) Even if the court is convinced that a person habitually commits crimes and that the community ought to be protected from, the court still has a discretion whether to make the declaration. [See S v Niemand (supra)].
[10] Once declared habitual criminal, the person "... may be kept in gaol for the rest of his life. He may be released on probation or on conditions. It is therefore a sentence that may operate with the utmost severity." [See R v Edwards 1953 (3) SA 168 (A)]. The discretion to be exercised must be exercised judicially.
[12] In the case before us, counsel for the Appellant has argued that when a declaration was made, the court a quo failed to make an inquiry into reasons for committal of the various offences of petty theft. This point was conceded by Ms Williams on behalf of the Respondent.
[13] With such concession made, it is the respectful view of this Court that the Court a quo did not exercise its discretion judicially when it made a declaration of the Appellant as an habitual criminal. The nature of the offences were not of violent nature and the Appellant was no danger to society.
[14] It follows therefore that the appeal must succeed.
ORDER
[15] The following order is made:
(a) The appeal is upheld.
(b) The declaration of the Appellant as an habitual criminal is replaced with the following sentence:
'The accused is sentenced to five years imprisonment two of which are suspended for a period of five years on condition that the accused is not convicted of a similar offence."
M.L.
SENYATSI
ACTING
JUDGE OF THE HIGH COURT OF
SOUTH AFRICA GAUTENG DIVISION, PRETORIA
I agree
B
NEUKIRCHER
JUDGE
OF THE HIGH COURT OF
APPEARANCES
For The Appellant: Mr R Du Plessis
Instructed by:
Legal Aid South Africa, Pretoria
For The Respondent: Adv Williams
Instructed by:
The Director of Public Prosecutions
Date of Hearing: 9 September 2019
Date of Judgment:
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