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SAFLII Note: Certain personal/private details of parties or witnesses have been redacted from this document in
compliance with the law and SAFLII Policy
IN THE HIGH COURT OF SOUTH AFRICA
WESTERN CAPE DIVISION, CAPE TOWN
CASE NUMBER: 9612/2023
In the matter between:
CITY OF CAPE TOWN Applicant
and
EREOMAX (PTY) LTD First Respondent
REGISTRAR OF DEEDS Second Respondent
ALL CONTRACTORS AND OTHER PERSONS Third Respondent
OCCUPYING OR BEING ON REMAINDER ERF 9[...],
RICHMOND PARK, CAPE TOWN
RICHLAND (PTY) LTD Fourth Respondent
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JUDGMENT DELIVERED ELECTRONICALLY, WEDNESDAY 27 NOVEMBER 2024
NZIWENI J
Introduction
[1] This case concerns a claim of ownership of land. The controversy finds its
genesis in whether the applicant has a legal right and entitlement to the land by
virtue of the operation of the law. The application is brought on behalf of the City
of Cape Town (“the City”). Although four respondents were cited in this matter, it
was argued only between the City and the first respondent.
[2] This is due to the following reasons: First, the third respond withdrew its
opposition and its counterclaim. Subsequently, the second respondent indicated
it would not contest the order sought by the City. The fourth respondent, who
developed the township in 1984 and sold the property to the first respondent in
2016 filed a notice to abide on 02 October 2023.
[3] The property at the centre of the controversy is described as the remainder of erf
9[...] Richmond Park, Cape Town, (“the property”) measuring 2 7876 hectares in
extent. The property is currently registered in the registry of deeds under the
name of the first respondent. In other terms, it is established that the registry of
deeds indicates the first respondent as the owner of the property. As such, the
first respondent claims title to the property by virtue of what is recorded in the
registry of deeds.
[4] In this instance, the City, however, contends that the property in question was
erroneously registered in / under the name of the first respondent. Therefore, it
seeks amongst others, a declaratory order.
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[5] The application was originally divided into two sections referred to as Part A and
Part B. In Part A, the City sought an interim relief pending the relief sought in [Part
B] this application. Part A dealt with an interdict aimed at, among other things,
preventing the first and third respondents from proceeding with 'unlawful'
construction activities or using the property in a manner inconsistent with its Open
Space 2 zoning and designation as a public park. Slingers J granted the requested
interdictory relief sought under Part A.
[6] In Part B, the applicant seeks amongst others, a final interdict to prohibit the
respondents from continuing with construction works; an order declaring that
the property vests in the applicant in terms of section 24 of the Township
Planning Ordinances 33 1934; alternatively, directing the second respondent to
deregister the property from the name of the first respondent and register the
property in the name of the applicant pending the outcome of an action to be
instituted by the first respondent within 15 court days, claiming vindicatory or
other relief regarding its alleged ownership or rights in the property. Additionally,
directing that if final relief is not granted in terms of paragraph 2.3 of Part A, the
first respondent must act within 30 days to:
Reinstate property to the state it was prior to commencement of the
unlawful construction.
Demolish any unlawful structures located on the property.
[7] At the commencement of this hearing, the first respondent requested a
postponement of the proceedings, to have an opportunity to respond to the
City’s supplementary affidavit. Pursuant to the application for postponement, the
City’s counsel did not persist in seeking leave from this Court to file the
supplementary affidavit. The City, in essence, chose to abandon the
supplementary affidavit.
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[8] To that end, the City’s counsel submitted that this Court should exclude the part
of the record starting from page 213. The parties have reached an agreement to
exclude the City’s supplementary affidavit from this hearing and have moved
forward with the hearing of this application.
Factual background
[9] The factual background of this case is largely agreed upon. A concise summary
of the background necessary to comprehend the parties’ contentions may be
briefly summarised as follows:
[10] In 1984, the fourth respondent undertook a township development project.
Therefore, the fourth respondent held e ownership of the township. The township
was established in terms of the Town-Planning and Townships Ordinance, 1986
(Ordinance No 15 of 1986). The property in question constituted the remainder of
the township, following the subdivision of the land.
[11] The subdivision plan designates the property as a public space under the zoning
classification of “Open Space Zone 2”. Despite this, the property in the deed’s
registry remained registered in the name of the fourth respondent [the developer].
[12] In 2016, the fourth and the first respondent entered into an agreement for the sale
and the purchase of the property. On 28 August 2016, the property was
transferred from the fourth respondent to the first respondent. The first respondent
bought the property for the sum of R725 000,00.
[13] The City only became aware of the property transfer in 2019. This is after a City’s
employee realised that the property was privately owned.
[14] In July 2020, the City instructed attorneys to investigate the matter and to register
the property in the name of the City. Following investigations by the City, in May
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2023, the City instructed its lawyers to attend to the transfer of the property to the
City.
[15] In May 2023, the City was alerted to a contractor working on the property and
building a boundary wall. At that point, the property featured playground
equipment and park installations that had been installed by the City 2-3 years
earlier.
[16] The boundary wall was constructed without obtaining approval for a building plan.
The first respondent was then served with notices to cease construction activities.
However, according to the City, the construction continued. The City, then
launched this application on urgent basis.
The scope of the application
[17] At the commencement of the oral submissions, Mr Fisher, on behalf of the first
respondent, informed this Court that it is the defendant's intention to clearly
delineate the specific issue upon which he wanted to confine his argument.
Although this application concerns various issues, however, the concern raised by
the first respondent pertains solely to a factual dispute. As such, the first
respondent’s written heads of argument were notably quite brief and did not fully
pursue all the assertions made in the answering affidavit. Thus, in the written
submissions filed by the first respondent and during oral arguments, the counsel
for the first respondent chose to concentrate his submissions on a single aspect
of this application.
[18] The first respondent’s opposition to the application therefore proceeded primarily
along one clear line of reasoning. The first respondent focused its argument on
insisting that this Court is not best equipped to deal with the nature of disputes
presented by the City in its papers. The first respondent argued that this is the
case because the aspect he chose to confine his submissions on should be
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determinative and dispositive of this application. Indeed, Mr Fisher argued that he
is not raising the matter as a preliminary issue, but as a substantive one.
[19] The first respondent, in advancing this argument, clearly defined and narrowed
the issue it sought for this Court to decide on. The controversy, as summarised by
the first respondent, revolves around whether the issues ought to have been
resolved through action proceedings.
[20] To that end, Mr Fisher made much of the dispute of facts in his submissions,
insisting that, the matter ought to have been referred to trial.
[21] With that in mind, it bears noting that, while the first respondent expended much
of its energy arguing that the matter should be referred to trial and chose to
primarily limit its submissions; the applicant on the other hand, has nonetheless
comprehensively addressed all the issues raised in the papers during its oral
submissions, including the aspect concerning the dispute of facts.
The parties’ submissions
Applicant’s submissions
[22] In the present case, the City has been at pains to point out that the application
pertains to matters of ownership and unlawful construction. The City asserts that
the property vested in it by operation of law, dating from as far back as 1984. For
the proposition that the property vested in the City, the City places reliance on
section 24 (1) of the Township Planning Ordinance No. 33 of 1934 “Township
Planning Ordinance”).
[23] According to the City, in the subdivision approval, the property is designated as a
public space. And the land use designation for the property is public park. The
City then provides the background as follows: As previously outlined, in 1984, the
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fourth respondent undertook a township development. The remaining portion of
the land from the subdivision for the development was designated as a public
place.
[24] It is the City’s assertion that the property remained designated as a public place
with open space zoning for some 32 years.
[25] According to the City, though vesting occurs automatically after confirmation of
the approved subdivision, formal registration in the name of the City seldom
occurred, at least before the advent of the Planning Bylaw. Thus, according to the
City, registration of the properties in the name of the City was seldom necessary.
City’s assertion regarding dispute of facts
[26] According to Mr Greig, the answering affidavit does not reveal a dispute as far as
vesting of ownership in terms of township ordinance is concerned. Mr Greig
further argued that the Court would seek in vain to find any dispute of facts
regarding the vesting of ownership in terms of the township ordinance.
Accordingly, Mr Greig submitted that, there is no dispute about the township
ordinance situation. The City reinforced its argument by stating that the first
respondent does not assert that;
a. there was something irregular about the township ordinance;
b. that the township ordinance does not apply as the City alleges;
c. does not deny that the piece of land was developed in 1984; and
d. there is no dispute of facts about the township ordinance situation.
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[27] Mr Greig developed these submissions during the course of his oral argument. He
submitted that as far as ownership is concerned, the law is unequivocal. He
pointed out that it is not disputed that the City is the true owner of the property.
[28] It is further asserted by the City that nothing is stated the first respondent’s papers
as to what occurred and how the sale had taken place in 2016.
[29] In this regard, Mr Greig emphasised that if the first respondent believes that it was
misled into thinking that they could register a public park and commence
construction on it, then their recourse is against Richland [fourth respondent] or
the auctioneers, not the City. This is so because the argument continues; the law
stipulates that the remaining portions vest in the City in terms of statute. As I have
already mentioned, Mr Greig predicates this contention upon the Township
Planning Ordinance.
[30] This being so, the argument proceeds to assert that the registered ownership is
not determinative and conclusive. The City’s counsel emphasised that in South
Africa the negative system of deeds registration is used.
[31] Mr Greig further submitted that the information contained in the deeds of registry
is not necessarily determinative or dispositive of the issue of ownership rights. If
an individual believes that the information in the deeds registry signifies
ownership or guarantees complete ownership of land, then that individual lacks
understanding of the registrar of deeds and what can be conveyed.
[32] Furthermore, the City argued that the Deed of registry merely serves as public
acknowledgement of ownership rights. In support of his argument, Mr Greig cited
an authority namely, Union Government (Minister of Justice) v Bolam 1927 AD
467.
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[33] Regarding the issuance of the rates clearance certificate by the City to the first
respondent during the transfer of the property from the fourth respondent to the
first respondent], it was submitted on behalf of the City that first respondent
cannot claim that the City indicated that the property could be transferred to them.
The City asserts that none of this ensures that genuine ownership of property has
been secured.
[34] Equally, the City contends that the issuance of a rate certificate does not imply
any representation regarding ownership in any manner. Rather, it serves as a
straightforward representation in terms of section 118 of the Municipal systems
Act, indicating that the rates and other end costs of the property have been
settled. It does not mean that the person can take ownership. The City only gave
approval to go ahead with the transfer, but this did not imply ownership.
[35] It is further submitted by the City that, although the first respondent does not
categorically state that it is relying on estoppel, there is a suggestion in the
answering affidavit that the City, by issuing the rates clearance certificate,
authorised the transfer. According to Mr Greig, in terms of relevance, this
assertion by the first respondent can only be understood through the lens of
estoppel. However, the City remains adamant that the first respondent cannot say
the City represented that the property can be transferred to them.
[36] Mr Greig further submits that estoppel must be based on unequivocal and
unambiguous representation. It is not representation by conduct. According to the
City’s counsel, the issuance of a rate certified is at best ambiguous regarding
property ownership. It does not meet the unequivocal requirement.
[37] As far as the building without approved plans is concerned, it is submitted on the
behalf of the City that it is not in dispute that the construction work on the property
was commenced without approved plans.
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First respondent’s submissions
[38] As previously mentioned, according to the first respondent, this matter involves
issues that should be litigated through a trial. Mr Fisher asserts that the first
respondent should be afforded an opportunity to show how he acquired the
property. This is particularly so due to the allegation made by the City that the first
respondent did not acquire the property in good faith.
[39] Mr Fisher further submits that; in order for the City to interfere with ownership
rights, it must do so through legal action. The discussion persists suggesting that
through this application, the City seeks to avoid action proceedings.
Consequently, complete justice remains unattainable. According to Mr Fisher, the
matter can only be adjudicated by way of action, specifically through rei vindicatio.
[40] To that end, Mr Fisher contends that it is not fair for the City to bring the issues
through motion, as this procedure does not allow for the full ventilation of all
issues involved. Mr Fisher submits that the City is required to substantiate their
claims, and must prove what they allege hence the matter cannot be resolved
through motion proceedings.
[41] Mr Fisher further asserts that once the property is registered in an individual’s
name, that person is recognised to be the owner unless proven otherwise. It is
further submitted on behalf of the first respondent that the City by issuing the rate
certificate was indicating that everything was in order. Mr Fisher also submits that
estoppel is a classical defence reserved for action proceedings.
[42] According to Mr Fisher, the City’s denial that the property was purchased
innocently constitutes a factual dispute. It is the first respondent’s contention that
it bought the property innocently and the law safeguards such owners. According
to the counsel for the first respondent, the issue of the import of the rate certificate
is a factual dispute.
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[43] In addition to the above, the respondent alleges before this Court that it is not
unlawful to build without approved plans. Mr Fisher submits that because this
Court has the version of the first respondent that states that it is allowed to build
first and then afterwards ask for permission. The first respondent contends that
that indicates a dispute of facts.
The issue
[44] While the papers highlighted several points, the issues were greatly focused
during argument to whether there are genuine dispute of facts that require a
referral to trial.
Evaluation
[45] The starting point is not that where there are disputes of fact, the disputes should
be determined at trial. In Plascon-Evans Paints (Tvl) Ltd v Van Riebeeck Paints
(Pty) Ltd 1984 (3) SA 620 the following was stated:
“when factual disputes arise in circumstances where the Applicant seeks
final relief, the relief should be granted in favour of the Applicant only if the
facts alleged by the Respondent in their Answering Affidavit, read with the
facts it has admitted to justify the order prayed for.”
[46] In this particular case, Mr Fisher faced a challenge in identifying the
disputed/contested facts. Instead, he maintained strongly that a dispute of this
kind, by its very nature, ought to have been litigated by way of action. The only
dispute of fact that he mentioned was the City’s assertion that the first respondent
did not acquire the property innocently, which constitutes a dispute of fact.
Additionally, the first respondent contends that construction without approved
building plans is not unlawful.
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[47] The City did not state in its papers that the first respondent did not obtain the
property innocently. In actual fact, it is discernible from the papers that it is not in
dispute how the parties claim entitlement to the property.
[48] It is as well to remind oneself at this stage that as far as the erection of the
boundary wall is concerned, it is a common cause fact between the parties that
the wall was erected without the approval from the City’s planning department.
The City also requires that this Court should decide whether the building work
was lawful. The dispute concerns whether construction work can proceed without
approved and sanctioned plans.
[49] In Walele v City of Cape Town and Others (2008 (6) SA 129 (CC), the law is
succinctly restated and set out by the Constitutional Court that the Building
Standards Act requires building plans to be approved for every building erected
within a municipal area and thus prohibits construction of buildings without the
prior approval of plans by the local authority within whose area a building is to be
erected. The Constitutional Court further acknowledged that a breach of this
prohibition constitutes a criminal offence punishable by means of a fine. The
same is true here. It is clear, therefore, that the first respondent in so far as it
suggests, it does not place reliance on any law for its proposition. Indeed, in my
view, the case of Walele supra provides an obvious contrast to the first
respondent’s proposition.
[50] I cannot quite comprehend and accept the proposition by the first respondent that
suggests that it is okay to break the law and remedy the consequence after the
fact. After all it is a striking known fact that no building work can commence within
a municipal area without prior approval of plans. Hence, there is an obvious oddity
around the fact that Mr Fisher argues with conviction that building work can
commence without prior approval of plans from the City. Obviously, such a
proposition may not, at the end of the trial, be found to be sufficient to carry the
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day. Moreover, as noted above, such submission is fundamentally flawed. As
such, it can never be regarded as a genuine dispute of fact.
[51] This Court is also called upon by the City to decide whether the property vests in
the City in terms of an ordinance. In other words, whether the ordinance trumps a
registered owner in the deeds of registry. As I have mentioned there was minimal,
if any disagreement, about the law contained in their submissions.
[52] While the parties differ as to how they are entitled to the same property, the
parties do not dispute what led to each one claiming ownership of the property.
This difference does not give rise to a genuine dispute of facts. In my view, the
issues presented by this application are purely legal in nature.
[53] It is therefore clear to me that whatever factual disputes present, does not
establish the existence of a genuine dispute of facts, but rather highlights the
parties’ dispute in legal conclusions based upon undisputed facts. Consequently,
there exist a degree of contention as to the legal import of the facts. As far as the
parties’ averments are concerned, the singular issue for determination concerns
the question as to which party is on the right side of the law.
[54] It follows then that the dispute between the parties’ centers upon the
consequences of applying the law to the undisputed facts.
[55] The City requests this Court to make a determination as to who is entitled to
judgment in terms of the law. Thus, it is a matter of the law. Put differently, the
questions involved here are questions of law and not questions of facts.
[56] To my mind the issues raised by the first respondent do not raise a legitimate
triable issue of genuine dispute of fact. The disputes between the City and the first
respondent are not factual disputes that necessitate a fact-finding exercise that
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would require a referral for oral evidence or trial. Hence, I even venture to say
that, in this case, the record does not present factual issues.
[57] Equally, this case does not present a situation where there is a disagreement
about the inferences that should be drawn from undisputed facts. Further and
significantly, the facts underlying all the relevant legal questions raised by the
pleadings or otherwise are undisputed. Even the facts concerning the construction
without approved plans.
[58] The papers in this matter do not set out any facts which suggest that there is
dispute of fact related to the issuance of the clearance certificate. The first
respondent does not sufficiently explain how the City’s issuance of clearance
certificate is a material fact regarding the ownership of the property, let alone one
requiring trial. The existence of the clearance certificate, in my view, is insufficient
to buttress the first respondent’s claim of genuine dispute of facts. In any event, it
does not advance the matter of ownership any further.
[59] It is so, that whether a representation was made could be a factual dispute.
However, a question that immediately begs is whether the representation is
material to the claim by the City such as to require a trial? In my opinion, it is not.
As far as the issuance of rate certificate, the lack of the essential requirements to
satisfy the defence of estoppel, renders the defence and the material facts
surrounding the alleged representation [as set out in the answering affidavit]
immaterial and irrelevant in this application.
[60] The answering affidavit in its current form, and even when interpreted generously,
only alleges a mere representation. The allegation of representation is merely a
bold solitary allegation that the City made a representation by issuing the rate
certificate. Even assuming for a moment that the City made such representation.
In what way does that deprive the City from the right that flows from the operation
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of the law? Perhaps it would have been different if it was alleged that the
representation was based on fraud.
[61] As mentioned earlier, the first respondent took a bold stance to assert that this
application can be disposed of on a narrow issue. Consequently, the narrow
issue argued by the respondent in response to the City’s application did not
constitute a defence to defeat the City’s claim for the relief mentioned in the notice
of motion.
[62] What does appear plainly is that the narrow argument approach adopted by the
first respondent, is that it did not account for the possibility of failure, regarding the
narrow point raised. At that moment, when Mr Fisher reduced the issues, I
distinctly did not get the impression that, in this application the issue is not about
the burden of proving ownership of the property; given the approach adopted by
the first respondent during the hearing.
[63] For that matter, during oral submissions, the City’s counsel submitted that there is
no dispute of facts in this application. In my view none of the first respondent’s
submissions have merit.
[64] If a respondent is opposing an application solely on the basis that there is a
genuine dispute of facts, an applicant is entitled to a relief if it is proven that there
is no genuine dispute fact. More so, if the facts demonstrate that the applicant is
entitled to such relief as a matter of law.
[65] The City’s contention is simple and straight forward: that the property vests in the
City by virtue of the law. On the other hand, the law states that the South African
system of registration is a negative system. According to the City, it acquired the
property in terms of the law and the acquisition does not reflect on the deed’s
registry.
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[66] In Cape Explosive Works LTD and Another v Denel (Pty) LTD 2001(3) SA 569 at
para 16 the following was stated:
“A real right is adequately protected by its registration in the Deeds Office (see
Frye’s (Pty) Ltd v Ries 1957 (3) SA 575 (A) at 582A). Once Capex’s rights had
been registered they were maintainable against the whole world (Frye’s case at
583E). They were not extinguished by their erroneous omission from subsequent
title deeds and the fact that Denel’s title deed, registered in the Deeds Office, did
not reflect those rights does not assist Denel. We have a negative system of
registration where the deeds registry does not necessarily reflect the true state of
affairs and third parties cannot place absolute reliance thereon (see Knysna
Hotel CC v Coetzee NO (396/96) [1997] ZASCA 114; 1998 (2) SA 743 at 753A-D;
Barclays Nasionale Bank Bpk v Registrateur van Aktes 1975 (4) SA 936 (T); and
Standard Bank van S.A. Bpk v Breitenbach 1977 (1) SA 151 (T) at 156C-E). In
Sakereg op cit at 342 the negative system of registration is explained as follows:
“In die geval van 'n negatiewe registrasiestelsel word nie gewaarborg dat die
inligting wat in die register vervat is, korrek is nie. Indien 'n bona fide derde dus
op die registers staatmaak, doen hy dit op eie risiko en word hy die slagoffer van
valse inliging in die register. Die ware eienaar verloor in geen omstandighede sy
reg ten gunste van die bona fide verkryger nie. Hierdie stelsel bied dus groter
sekuriteit aan die ware eienaar as aan die bona fide derde wat die slagoffer van
'n foutiewe inskrywing kan word.”
And later on the same page:
“Hoewel eiendom en beperkte saaklike regte nie sonder registrasie oorgedra kan
word nie, word nêrens gewaarborg dat die aktesregister 'n juiste beeld van die
ware toedrag van sake gee of dat derdes absoluut daarop kan staatmaak nie.”
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[67] In light of the facts of the current matter I have no hesitation whatsoever that the
submissions of Mr Greig are to be preferred. I, of course, also agree that if a party
is referred to as an owner of a property in the deed’s registry, it does not
necessarily mean that the party in every case is the true owner. Put differently,
the registration of title in the deeds office does not establish incontrovertible
evidence of ownership of the immovable property. This is so because the deeds
office cannot guarantee the accuracy or truthfulness of the information on their
registration system. Therefore, a party cannot rely exclusively on the accuracy or
completeness of information contained therein, to claim ownership of a property.
[68] The argument presented by the City is further supported by the case of Union
Government supra, where the Appellate Division succinctly articulated that when
a statute regulates the ownership of land, registration must necessarily give way
to the provisions of the statute.
[69] In these circumstances, the applicant’s argument is made with much greater
plausibility. Accordingly, the City has succeeded to prove its entitlement to the
property and the unlawfulness of the building work on the property. Another
significant issue is that of costs
Costs
[70] The City requested that costs in respect of the first respondent should be awarded
on a punitive scale. In so far as the third respondent is concerned, the City seeks
an order in respect of its opposition of the matter and its counter application.
[71] The ordinary rule is that the costs follow the event. Of course, this Court still has a
discretion. The exercise of that discretion can be informed by the particular facts
before the court. The question that readily springs to mind is whether the normal
rule is unsuitable on the facts of this case.
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[72] This matter raised unique facts in relations to parties claiming title to ownership of
the same property and no blame can be attached to either party for the stalemate.
It cannot be said that the issue that was involved in this matter has been
frequently and recently litigated in previous cases.
[73] In the context of this matter, it is my view that no blame can be attached to the
first respondent for opposing the matter out of a bona fide concern to vindicate its
perception of ownership. Similarly, it can also not be said that the first respondent
engaged in vexatious, frivolous or abusive conduct. These factors weigh heavily
in favour of departing from the usual approach to costs. This also applies to the
third respondent
[74] In the result, I make the following order:
ORDER:
1. It is declared that the property described as the remainder of erf 9[...] Richmond
Park, Cape Town, (“the property”) vests in the City of Cape Town (“the applicant”)
arising from section 24 of the Township Planning Ordinance 33 of 1934, Western
Cape, and/or section 58 of the Municipal Planning Bylaw, and so vested since
1984.
2. The second respondent is hereby directed to register the property in the name of
the applicant;
3. The first and the third respondent are interdicted from:
3.1 Carrying on any excavation, building or other construction works at or on
the property;
3.2 Taking any vehicles onto the property; and
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3.3 Occupying or using the property in any manner other than as a public park
or as permitted by zoning of the property as “Open Space 2” in terms of
the Planning By law;
4. It is further declared that any building structure erected on the property by the
first and the second respondents, has been unlawfully erected.
5. The first respondent is hereby directed to demolish any unlawful structures
located on the property within 30 days.
6. Failing compliance with paragraph 5, the applicant may apply on the same
papers, duly supplemented as may be necessary, for an order authorizing it or its
agents or contractors, assisted as may be necessary by the Metropolitan and
South African Police Service, to reinstate property to the state it was prior to
commencement of the unlawful construction, and to demolish any unlawful
structures located on the property, at the first respondent’s costs.
7. Each party to pay its own costs.
---------------------------------------------
CN NZIWENI
JUDGE OF THE HIGH COURT
Appearances
Counsel for the Applicant: Adv. MA Greig
Instructed by: Fairbridges Wertheim Becker
Ref: D Olivier
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Counsel for First Respondent: Adv. W Fisher
Instructed by Karin Houston Attorneys
Ref: Karin Houston