Johannesburg Water (Soc) Ltd v Dark Fibre Africa (Pty) Ltd (A2023/081149) [2025] ZAGPJHC 459 (14 May 2025)

82 Reportability
Administrative Law

Brief Summary

Public Law — Organ of State — Definition under the Legal Proceedings Act — Johannesburg Water, established to provide water services, deemed an organ of state. Dark Fibre claimed damages for cable damage caused by Johannesburg Water's contractors. Johannesburg Water raised a special plea for lack of notice under section 3 of the Legal Proceedings Act. The court held that Johannesburg Water is an organ of state as it performs a constitutional function, thus requiring compliance with the notice provisions of the Act. The appeal was upheld, and the matter was referred back for consideration of condonation for the notice failure.

Comprehensive Summary

Case Note


Case Name: Johannesburg Water v Dark Fibre

Citation: [Not provided, refer to the judgment text]

Date: [Not provided in the judgment text]


Reportability


This case is reportable because it addresses the fundamental issue of whether an institution such as Johannesburg Water may be treated as an “organ of state” under the Legal Proceedings Act. The judgment outlines the significance of determining the correct characterization of an institution that performs a constitutional function, in this case, the provision of water as a basic municipal service. This determination is crucial for regulating the state’s liabilities and the prelitigation notice process, which has broader implications for state accountability and debt collection procedures.


The decision also highlights important considerations in interpreting statutory provisions that govern which entities fall within the ambit of the Legal Proceedings Act. The analysis of the function performed by Johannesburg Water in light of constitutional obligations underscores the importance of aligning statutory interpretation with constitutional values. In doing so, the court confirms that it is the function of the institution, and not merely its form or regulatory framework, that determines its status as an organ of state.


Finally, the judgment is of importance to future cases where the distinction between purely private entities and those performing constitutional functions is in question. The analysis helps clarify the boundaries of liability and state underwrite when institutions are set up to fulfill essential public services.


Cases Cited


Haigh v Transnet Ltd 2012 (1) SA 623 (NCK)

Nicor IT Consulting (Pty) Ltd v North West Housing Corporation 2010 (3) SA 90 (NW)


Legislation Cited


Institution of Legal Proceedings Against Certain Organs of State Act 40 of 2002

Constitution of the Republic of South Africa, 1996

Municipal Systems Act 32 of 2000

Companies Act 71 of 2008

Public Finance Management Act 1 of 1999


Rules of Court Cited


Magistrates’ Court Rules, specifically Rule 51


HEADNOTE


Summary


In this case, the court was required to determine whether Johannesburg Water qualifies as an “organ of state” within the meaning of the Legal Proceedings Act. The central issue involved whether the institution’s sole function of providing water as a basic municipal service constitutes performance of a constitutional function. The court held that the nature of the function performed is the key determining factor.


The judgment explains that although Johannesburg Water does not derive its powers directly from the Constitution, its exclusive and dominant purpose is to carry out a constitutional function. This role places it within the scope of the Legal Proceedings Act despite the fact that its regulatory framework comes from various statutes such as the Municipal Systems Act and the Companies Act. The court’s reasoning dismisses arguments based solely on the source of power or direct constitutional derivation.


Furthermore, the court articulated that the state has an interest in tracking liabilities incurred through constitutional functions. This reasoning supports the conclusion that Johannesburg Water is an organ of state, ensuring that the prelitigation notice procedure under section 3 of the Act is applicable. The decision clarifies how entities performing essential public services are to be treated under the law.


Key Issues


The key legal issues addressed in the judgment include:

- Whether the performance of a constitutional function must be derived directly from the Constitution in order to qualify an institution as an “organ of state”

- The significance of the function performed by Johannesburg Water in determining its status

- The implications for the prelitigation notice procedure required by the Legal Proceedings Act when dealing with state liabilities


Held


The court held that Johannesburg Water is indeed an organ of state under the Legal Proceedings Act. The decision was based on the recognition that the institution’s exclusive purpose is to perform a constitutional function—namely, the provision of water as a basic municipal service. As such, despite not deriving its powers directly from the Constitution, Johannesburg Water meets the criteria by performing a function in terms of the Constitution. The court remanded that Dark Fibre must now seek condonation for its failure to provide notice under section 3 of the Act.


THE FACTS


Johannesburg Water is a municipal entity set up under the Municipal Systems Act and wholly owned and controlled by the City of Johannesburg. Its explicit function is to provide water to the residents of Johannesburg, thereby performing an essential constitutional function under sections 27(1)(b) and 152(1)(b) of the Constitution. The respondent, Dark Fibre, which owns a network of underground fibreoptic cables, alleged that contractors working for Johannesburg Water negligently damaged one of its cables during work on an underground water pipe in Greenside, Johannesburg.


The claim by Dark Fibre sought recovery of the reasonable cost of repairs for the alleged damage, amounting to just over R320,000. In its defense, Johannesburg Water argued that Dark Fibre failed to comply with the notice requirement set out in section 3 of the Legal Proceedings Act, a prerequisite for any claim against an organ of state. Dark Fibre, in turn, contended that Johannesburg Water was not an organ of state, thus challenging the applicability of the notice requirement.


Ultimately, the lower court ruled in favor of Dark Fibre, accepting the special plea regarding the lack of proper notice. Johannesburg Water appealed this decision, leading to the analysis and findings detailed in the judgment under discussion.


THE ISSUES


The legal questions before the court revolved around the proper interpretation of what constitutes an “organ of state” under the Legal Proceedings Act. The court needed to decide whether the institution’s setting and regulatory framework should affect its status, or if the primary consideration should be the function it performs. Additionally, the court addressed whether the failure to serve notice, as stipulated under section 3 of the Act, could be excused or whether it should effectively bar Dark Fibre’s claim if Johannesburg Water were indeed regarded as an organ of state.


Furthermore, there was a debate regarding whether an institution must derive its powers directly from the Constitution in order to perform a constitutional function. The court was asked to reconcile the reasoning applied in previous cases such as Haigh and Nicor with the practical and constitutional considerations of municipal service provision. These issues aimed to clarify the extent of state liability and the mechanisms for debt collection when funds are claimed against state entities.


ANALYSIS


The court analyzed the statutory requirements of the Legal Proceedings Act alongside the underlying constitutional purpose of institutions performing public functions. The key point emphasized was that the exclusive or dominant aim of the institution is central. Johannesburg Water was established solely to perform the constitutional function of providing water to the residents of Johannesburg. The court reasoned that it is immaterial whether the institution derives its powers directly from the Constitution; rather, the focus should be on the nature and purpose of the functions it performs.


The reasoning involved a detailed discussion of precedents such as Nicor and Haigh. The court critically examined the proposition that an institution must explicitly derive its powers from the Constitution, finding this approach too narrow. Instead, it supported a broader interpretation where the performance of a constitutional function—despite regulation by other statutes such as the Companies Act or the Municipal Systems Act—is sufficient for classification as an organ of state. The judgment noted that such an interpretation is necessary to avoid absurd results, such as erroneously classifying non-governmental organisations with charitable objectives as organs of state simply because they perform functions that relate to constitutional entitlements.


The court also emphasized the practical need for the state to monitor liabilities incurred by bodies carrying out constitutional functions. By regarding Johannesburg Water as an organ of state, the law ensures that creditors like Dark Fibre provide early notice of their claims. This measure safeguards the financial interests of the state and reinforces the accountability mechanism set forth in the Legal Proceedings Act.


REMEDY


The remedy provided by the court was to overturn the Magistrate’s decision regarding the special plea. The court held that Johannesburg Water’s status as an organ of state meant that it was entitled to the statutory notice under section 3 of the Legal Proceedings Act. Consequently, Dark Fibre must now seek condonation from the lower court for its failure to serve the required notice. This remedy ensures that the proper procedural framework is applied to the claim, aligning with the Act’s objectives of adequately tracking state liabilities.


The decision does not end Dark Fibre’s claim. Instead, it remands the case to the lower court where the applicant must demonstrate good cause and establish that the claim has not prescribed. The emphasis on following proper notice procedures is critical to maintain the integrity of claims against organs of state. The remedy thus underscores a balanced approach between state accountability and procedural fairness.


LEGAL PRINCIPLES


The judgment establishes the key legal principle that an institution can be deemed an “organ of state” not solely on the basis of its source of power but predominantly on the nature of its functions. The dominant principle is that if an entity is organized to perform a constitutional function—even if regulated by external statutes—it falls within the ambit of the Legal Proceedings Act. This interpretation ensures that the state’s financial liabilities remain transparent and properly accounted for under established legislative processes.


Additionally, the decision clarifies that a rigid requirement for powers to be derived directly from the Constitution would yield impractical results and neglect the broader purpose of the entity. The court’s reasoning prioritizes the purpose and extent of the services rendered by the institution over its formal constitutional derivation. Lastly, the judgment reinforces the importance of adhering to statutory notice procedures when claims are made against bodies performing state functions, thereby promoting consistency and accountability in state financial matters.

2
WILSON J (with whom MABESELE J agrees):

1 The central question in this case is whether the appellant, Johannesburg
Water, is to be treated as an “organ of state” within the meaning given to that
term in the Institution of Legal Proceedings Against Certain Organs of State Act 40 of 2002 (“the Legal Proceedings Act”). In this judgment, we conclude that Johannesburg Water is an organ of state so defined, because it is an institution “performing a function in terms of the Constitution” under section 1
of the Legal Proceedings Act. The nature of that function is the provision of water as a basic municipal service under sections 27 (1) (b) and 152 (1) (b) of the Constitution, 1996 . Johannesburg Water was set up in terms of the
Municipal Systems Act 32 of 2000 (“the Systems Act”) to perform that function, and only that function, for the residents of Johannesburg. The mere fact that its activities are directly regulated by the Systems Act, the Companies Act 71 of 2008 and a contract with the City of Johannesburg, rather than by the
Constitution itself, makes no difference to the reality that it performs one of the
State’s constitutional functions, and is accordingly an organ of state under the Legal Proceedings Act.
The dispute
2 The respondent, Dark Fibre, owns and controls a network of underground
fibreoptic cables. It sells or leases the use of those cables to other entities who
require means of data transfer, whether for telecommunications, access to the internet, or otherwise. Dark Fibre says that Johannesburg Water, or contractors working for it, negligently damaged one of Dark Fibre’s cables while performing work on an underground water pipe in Greenside,
3
Johannesburg. Dark Fibre instituted proceedings in the Johannesburg
Regional Court claiming just over R320 000 for what it said was the reasonable cost of repairing the damage caused.
3 Section 3 of the Legal Proceedings Act obliges anyone claiming a “debt”
against an organ of state to deliver, within six months of the debt falling due, a notice setting out the facts giving rise to the debt and the particulars of the debt insofar as these are known to the claimant. In defending Dark Fibre’s action, Johannesburg Water contended that Dark Fibre claimed a “debt” as defined in the Legal Proceedings Act, and raised the special plea that Dark Fibre had failed to give Johannesburg Water the notice section 3 requires.
4 The failure to deliver a section 3 notice can be condoned, but Dark Fibre did
not seek condonation. It instead argued that Johannesburg Water is not an organ of state within the meaning of the Legal Proceedings Act, and was for that reason not entitled to notice under section 3. The Magistrate below agreed with Dark Fibre and dismissed the special plea. Johannesburg Water now appeals.
The appeal
5 The Magistrate’s reasons are not easy to discern, but it seems from his
judgment ex tempore that the Magistrate took the view that, because
Johannesburg Water is not a national or provincial department of state, it
cannot be regarded as an organ of state for the purposes of the Legal
Proceedings Act. When given an opportunity to supplement his reasons under
Rule 51 of the Magistrates’ Court Rules, however, it appears to have occurred
to the Magistrate that what matters under the Legal Proceedings Act is the
4
nature of the function an institution performs, rather than the identity or
affiliation of the institution that performs it. This is consistent with section 1 of
the Legal Proceedings Act, which sets out that an organ of state includes any
functionary or institution which exercises “a power or perform[s] a function in terms of the Constitution” – whether it is housed in a state department or not.
6 Nonetheless, relying on the decision in Haigh v Transnet Ltd 2012 (1) SA 623
(NCK) (“Haigh”), the Magistrate appears to have considered that Johannesburg Water could not be an organ of state under the Legal Proceedings Act because, though it performs a constitutional function, it does not do so “in terms of the Constitution”. In other words, the Magistrate appears to have reasoned that Johannesburg Water is not an organ of state because
it does not derive its powers or functions directly from the Constitution. The Magistrate does not spell this theory out in his written reasons. However, it
seems to me that this is the approach that in fact underpins those reasons.
Johannesburg Water is an organ of state under the Act
7 The approach I have imputed to the Magistrate below is ultimately derived
from the decision in Nicor IT Consulting (Pty) Ltd v North West Housing
Corporation 2010 (3) SA 90 (NW) (“Nicor”), which the decision in Haigh
followed. At paragraphs 7 to 14 of Nicor, Lever AJ reasons that an institution
does not “exercise a power or perform a function in terms of the Constitution”
unless it derives its powers or functions directly from the Constitution. On the
reasoning in Nicor and Haigh, Johannesburg Water is not an organ of state
under the Legal Proceedings Act because it is neither mentioned in, nor derives its powers or functions directly from, the Constitution. The fact that it
5
indisputably performs a Constitutional function, by providing water to the
people of Johannesburg, is of no moment.
8 It appears to have weighed with the court in Nicor that to hold otherwise might
lead to absurd results: “[i]f, for example, a non-government organisation (NGO) had as its main objective the raising of funds for the provision of low-cost housing and in fact provides such housing to the indigent in South Africa . . . [it] would be an 'organ of State' and it would be entitled to notice . . .
within six months, as contemplated in s 3 of the Act” (Nicor paragraph 12).
9 These misgivings notwithstanding, it seems plain to me that Nicor and Haigh
were wrongly decided, at least on the point in issue. What matters is not the
proximity between the powers the institution exercises and the constitutional text, but whether the exclusive or dominant purpose of the institution is to exercise or carry out one o r more of the State’s constitutional powers or
functions.
10 This approach to the question, it seems to me, caters fully for the concerns
expressed in Nicor. It properly includes institutions, such as Johannesburg
Water, which are set up by the State and held at arms-length, but whose very purpose is to perform a function under the Constitution . It nonetheless
excludes contractors who may happen to perform constitutional functions on
the State’s behalf without that being their main purpose , or non-governmental
organisations whose main purpose is to give effect to a constitutional
entitlement as an act of charity, rather than because the non -governmental
organisation is obliged by the Constitution to do so.
6
11 The need to draw this distinction is central to the purposes of the Legal
Proceedings Act. The Act seeks to regulate the process for collect ing debts
owed by organs of state. One feature of the process the Act sets up is the
prelitigation notice procedure to which Johannesburg Water says it is entitled
in this case. The idea is that the State, and the various institutions performing
constitutional functions on its behalf, will likely incur substantial liabilities while
exercising constitutional powers or performing constitutional functions. Those
liabilities are ultimately underwritten by the State as a whole. A process is
required to allow the State as a whole to keep track of its liabilities. Early notice
of a creditor’s claim, which is what section 3 provides for, is part of that process.
12 Johannesburg Water is a case in point. Johannesburg Water derives none of
its powers or functions directly from the Constitution. Nor does it describe itself
as an organ of state. It is nonetheless a municipal entity established as a
private company in terms of section 86B of the Municipal Systems Act. It is wholly owned and controlled by the City of Johannesburg (see 86G of the Municipal Systems Act). It is subject to the Public Finance Management Act 1
of 1999 . It must restrict its activities to those that the City of Johannesburg
would other wise legitimately undertake, and it has no competence to
undertake any others (see section 86D (1) (b) of the Municipal Systems Act).
In other words, Johannesburg Water’s only purpose is to provide water to the residents of the City of Johannesburg . The delict Dark Fibre alleges in the
court below was committed in the course of doing just that.
7
13 It is, in my view, untenable to suggest that Johannesburg Water is not an organ
of state simply because it does not derive its powers and functions directly
from the Constitution. The City in particular, and the State as a whole, clearly
have an interest in keeping track of Johannesburg Water’s liabilities in the manner that the Legal Proceedings Act prescribes. This is because Johannesburg Water’s assets and liabilities are the City’s assets and liabilities. For that reason, Johannesburg Water’s liabilities are ultimately underwritten by the State itself.
14 It follows that Johannesburg Water is an organ of state for the purposes of the
Legal Proceedings Act because it is an institution performing a function in
terms of the Constitution: the provision of water as a basic municipal service
under sections 27 (1) (b) and 152 (1) (b) of the Constitution.
Relief
15 Accordingly, the court below should have upheld the special plea. Mr. van der
Merwe, who appeared for Johannesburg Water before us, conceded that this
does not spell the end of Dark Fibre’s action. It means only that Dark Fibre must now ask the court below to condone its failure to give the notice section 3 of the Legal Proceedings Act requires. The court below will grant that application if good cause has been shown, if Dark Fibre’s claim has not
prescribed, and if Johannesburg Water was not prejudiced by the failure to give notice. On the facts of this case, these seem to me to be slight hurdles indeed.
16 Ultimately, though, that is a question for the court below. Dark Fibre’s action
should be stayed until the court has had an opportunity to answer it.