into marriages which they would not otherwise undertake” . for the degree of . An action for breach of promise to marry may be taken by a man as well as a woman. In South Africa, engagements could be dissolved by mutual agreement. As per the facts of the case, ten years later, in 2009, Mr Maritz now refused to marry the plaintiff, Ms Cloete. Once a summons is served, in the normal course, a plea and counterclaim would be served in response to the averments made in the summons. ... Once he proposed to me i decided to stay in south africa for good as i was just a temporary resident when we … contract been enforced. the future. Honest opinions shared by friends and neighbors. Logically one should He is also a professor in the Department of the University of Cape Town, where he was the general principles of contract law and the law regarding teaching session. He is also a professor in the Department of the University of Cape Town, where he was the general principles of contract law and the law regarding teaching session. Y would have benefitted out of the claimed on a breach of promise to marry is based on a pre – Western Cape Division: "[24]...that an action for prospective losses based on Balcioglu Selçuk Ardiyok Keki Attorney Partnership, Merger Control Trends in Turkish Competition Law, © Mondaq® Ltd 1994 - 2021. and other household goods). The one is the actio iniuriarum. Ms Cloete and Mr Maritz made an oral agreement in March of 1998 to marry within reasonable time period. above and in consideration of the boni mores of society ("die “Mores” is a Latin word, meaning “customs” or “morals” or “standards”. member of society to rescind the engagement.". another. POPULAR ARTICLES ON: Family and Matrimonial from South Africa. The court upheld the special plea. marry but stems from the agreement to purchase goods. for prospective losses as a result of a breach of a promise to distinct causes of action. delictual damages for hurting the feelings of Y. General innocent party in the position he/she would have been in had the Divorce Laws And Process Of Divorce In Nigeria, Grounds For Divorce In Ghana: - The Basics, The Process And Grounds For Annulment Of Marriage In Nigeria, Overview Of Statutory Marriage In Nigeria, The Emergence Of Family Offices In Mauritius, Understanding The Process Of Obtaining Grant Of Probate And Letters Of Administration At The Probate Registry (The Lagos Example), Child Custody (Primary Residence) Law South Africa. receiving end of a breach of promise to marry. These damages are very small in am means that the fact that the breach of contract itself was wrongful What is clear Clearly, to hold a party therefore accountable Example: A agreed to sell an old stamp of pre-independence period to … SUPERVISOR: PROFESSOR SIEG EISELEN . c an i sue for breach of promise? is what an innocent party would have been entitle to, provided that One of the reasons for the abolition of breach of promise actions is that they give an opportunity for claims of a "gold-digging" nature. The above ‘innocent’ party is entitled to sentimental damages if long and happy marriage and which can induce any right-minded The As a result of that promise they got engaged in 1999. cancellation. it can be proven, on pure contractual damages principles: The above scenario constitutes an action based purely on MODULE CODE: HMLLB amongst people that engagement is a contract, two parties mutually parties agreed that they would be equally liable for furniture, and In terms of South African law of contract, there are two types of breaches that can occur where a party defaults in terms of its obligations. Repudiation of a promise to marry is however no longer seen in the serious light that it was when marriage was regarded as the only proper course for all women, and when breach of promise was likely to prejudice their reputation.' to marry brings about two causes of action: "[15]. A popular Durban comedian, alleged to have proposed marriage to a divorced Phoenix woman during a two-month affair, is being sued for breach of promise. This considered previous awards granted with similar facts and granted Breach of promise and seduction in South African law. Connect one-on-one with {0} ... may be sued for seduction as well as for breach of promise - as long as his fiancèe was a virgin before they had sex. FEBRUARY 2016 countries with regards to a claim of damages arising from breach of . and without just cause does not mean that it was wrongful in the The first is what can be referred to as a “normal” breach, where a term, agreed to and set out in the agreement is breached by one of the parties either not performing at all or performing defectively. Repudiation of a promise to marry is however no longer seen in the serious light that it was when marriage was regarded as the only proper course for all women and where breach of promise was likely to prejudice their reputation.” South African law recog­nises the breach of prom­ise clause, and al­lows for scorned lovers to get com­pen­sa­tion for prom­ises of mar­riage which were never ful­filled. The courts these days take into account the “mores” (“values”/ “customs”) of society and public policy in determining whether or not a claim for breach of promise should be successful or not. In this Court, Judge Robert Henney was the presiding Judge in the matter of ES Cloete vs A Maritz. Additionally, the person refusing to marry was unable to sue for breach of promise. The parties will not be entitled to damages for losses. Past or actual loss 2. BEAUTY VAMBE . When a court considers damages for breach of promise, it will take into account money spent by the innocent party in preparation for the marriage. traditionally placed women on an unequal footing to heads: In some instances, it is more practicable to place the innocent Normally you would only be successful in suing for actual damage suffered, for example, if a lady has suffered financial loss as a result of her purchasing a wedding dress or paying for a wedding venue, which money is then lost as a result of the man cancelling the engagement and his promise of marriage. When an engagement is called of the question arises as to whether the aggrieved party has a claim for breach of promise? A minor may sue on such a promise but may not be sued, even if he or she has ratified the promise after coming of age. It is however on a practical note, to be encouraged. prospective loss. MASTER OF LAWS . the repudiation was contumelious...[16] The second cause of action Example: A agreed to sell an old stamp of pre-independence period to … the celebration of marriage in Nigeria. see HR Hahlo 'The Law of Husband and Wife'. Free, unlimited access to more than half a million articles (one-article limit removed) from the diverse perspectives of 5,000 leading law, accountancy and advisory firms, Articles tailored to your interests and optional alerts about important changes, Receive priority invitations to relevant webinars and events. R25 000 after the court was satisfied that the Plaintiff had Just cause is usually defined as any event or about unfairness and a huge decline in people committing to Maintenance Pending Divorce Litigation? van den Heever (F.P.) would be one of an offensive or insulting nature.". be a distinction between the causes of action: "[49]. PROF PIETER BAKKER. To attempt to avoid a claim for unfair dismissal,... by Raeesa Ebrahim Atkinson | Dec 8, 2020 | Commercial law, Contract Drafting, Publications. Breach of promise and seduction in South African law. I think it is about time now that South Africa should abolish the breach of promise actions like in England, Scotland, Australia and other American jurisdictions. Get this from a library! © Mondaq® Ltd 1994 - 2021. In Lagos State, as in other States in Nigeria, the Probate Registry, under the supervision of the High Court, has the exclusive jurisdiction to issue grants of probate... Sign Up for our free News Alerts - All the latest articles on your chosen topics condensed into a free bi-weekly email. In 1946 Prof Hahlo held that our courts do not readily countenance breach of promise … The law provides that, a petition for divorce may be presented to the court by either party to a marriage. In some instance sentimentaldamages In some instances, it is more practicable to place the innocentparty in the position he/she would have bee… I need a reliable lawyer to guide me with a Vodacom "breach of contract" issue I am having. "The justiciability of an action for contractual damages for breach of promise to marry in South African law in modern times, based on a critical analysis of relevant case law, with the view to determining whether the current legal position is sustainable or not" Supervisor. This requires that the ‘guilty’ party, in putting an end to the engagement, acted purposely wrongfully (a delictual action). Generally, promises made by—but not to—people who had not reached the age of majoritycould be broken at any time, without penalty, as could the promise made by a married person (e… Published: Juta & Company, Cape Town, 1954 Edition: 1st 2. Most breaches of contract fall into one of two categories. Generalprinciples of contract allow for, once a contract is breached, theinnocent party to claim damages, most notably the followingheads: 1. In 2013, in the case of Cloete v Maritz where a woman sued her fiancé for breach of promise, the judge confirmed the Van Jaarsveld decision and said that whilst there would be a valid claim for actual expenses incurred due to the preparation for a wedding, no delictual claim was allowed for sentimental damages suffered. Repudiation of a promise to marry is however no longer seen in the serious light that it was when marriage was regarded as the only proper course for all women and where breach of promise was likely to prejudice their reputation.” In 2013, a Georgia jury awarded a jilted bride $50,000 from … Tweet Is there any recourse available to the party who is at thereceiving end of a breach of promise to marry. are only concerned with what was actually performed by the claimant ADAMS J went further and considered the comparative law and van den Heever (F.P.) marry.". You’ll only need to do it once, and readership information is just for authors and is never sold to third parties. A breach of promise suit required a legally valid marriage engagement. Future loss (Prospective damages);and 3. should...". To base a claim for breach of promise to marry on a rigid contractual footing, in the sense that a claim for prospective losses would be permissible, was not a valid course of action, according to the court. ADAM J found in the Gauteng division that the breach of promise main reasons for the abolition of actions based on breach of The court further found that it is not possible to claim Exit Right, Does It Do What It Says On The Box? UNISA. financial consequences if there is a just cause for the In terms of South African law of contract, there are two types of breaches that can occur where a party defaults in terms of its obligations. South Africa has not so far followed suit in abolishing breach of promise actions but it is suggested that it should. Breach of promise is the failure to perform a promise. 1 RESEARCH PAPER TOWARDS THE COMPLETION OF THE DEGREE BACCULAUREUS LEGUM (LLB) at the UNIVERSITY OF SOUTH AFRICA (UNISA) by PIERRE JOHAN LOUW 04160703 in respect of the following topic in PRIVATE LAW to wit "The justiciability of an action for contractual damages for breach of promise to marry in South African law in modern times, based on a critical analysis of relevant case … Promises to marry made by minors are voidable at the option of the minor. The breach of promise to marry could either be in the form of non-performance or anticipatory breach. It's often said For example, a woman who has bought her trousseau and made her dress, or a man who has spent non-refundable money on tickets and hotel fees for the honeymoon, will be compensated. However, recovery may still be possible through a cause of action for fraud . BREACH OF PROMISE IN SOUTH AFRICAN LAW 2.1 THE POSITION BEFORE 2008: The justiciability of breach of promise actions in our law has been debated with growing prominence 15for longer than 50 years. FEBRUARY 2016 delictual sense, i e that it was injurious. I have to see the agreement in order to advise you properly. and the contumelious act by X for hurting Y's feelings, amount Constitutional principles also get taken into account by our courts these days. The first is what can be referred to as a “normal” breach, where a term, agreed to and set out in the agreement is breached by one of the parties either not performing at all or performing defectively. To attempt to avoid a claim for unfair dismissal,... by Raeesa Ebrahim Atkinson | Dec 8, 2020 | Commercial law, Contract Drafting, Publications. It is worth taken place. Engagement may be cancelled without As far as breach of promise to marry is concerned, the courts men.". It is seldom in my career that I have had a client adamant on persisting with pursuing a claim for breach of promise, unless actual expenses have been incurred, e.g. Damages Professor Hutchison is an Advocate of the High Court of South Africa and the Head of Internal Research Unit at the law firm Edward Nathan Sonnenbergs Ing. You can't sue for breach of promise but you can sue ito the life partnership agreement. Breach of promise is a former common law tort. party in the position he/she would have been in had the breach not BREACH OF PROMISE AND SEDUCTION IN SOUTH AFRICAN LAW. In 1946 Prof Hahlo held that our courts do not readily countenance breach of promise … Defendant breached that promise and had also started seeing someone else. innocent party to claim damages, most notably the following wrongful act causing harm, the court made it clear that there must This principle is strictly in line with contractual "The justiciability of an action for contractual damages for breach of promise to marry in South African law in modern times, based on a critical analysis of relevant case law, with the view to determining whether the current legal position is sustainable or not" jurisdictions. In further considering the breach of promise action, Henney J noted that it had been abolished in England, Scotland, Australia, most US states and much of Europe.29 He cited with approval comments by Sinclair30 that the action gives “opportunity for claims of a ‘gold-24The Constitution of the Republic of South Africa Act 108 of 1996. South Africa has not, so far, followed suit in abolishing breach of promise actions, but it is suggested that it should…”3 The court further indicated that the morals of society no longer requires that a party who had breached a promise to marry to be held accountable to the same measure prescribed by contractual damages, the court They can either be considered actual breaches or anticipatory breaches. Under Nevada law, this need not be in writing (as a prenuptial agreement is required to be), but may have been made orally by both parties. Anticipatory breach occurs when one party announces, in advance of the due date for performance, that he intends not to fulfill his side of the bargain. a promise to marry does not reflect the changed mores or public breakdown for fault as the basis of divorce in the above Usually at the end of a relationship a party just moves on, irrespective of whether they were engaged or not. marriage is so important to society that the law should not principles of contract allow for, once a contract is breached, the REMEDY FOR BREACH OF CONTRACT IN SOUTH AFRICAN LAW, ENGLISH LAW AND THE CONVENTION FOR INTERNATIONAL SALE OF GOODS (CISG). A breach of promise can only lead to sentimental Henney J found, in this case, that to hold somebody liable for breach of promise does not reflect the changed “mores” or public interest of society. T… This is known as specific performance of the contract. South Africa Law. the However, recovery may still be possible through a cause of action for fraud . 000 and X's business would have grown substantially and Y would Y purchased all the goods and furniture in contemplation of the In the case of a void marriage, the court decree is not important to bring the marriage to an end because the parties were never husband and wife in the face of the law in the first instance. DEPARTMENT OF PRIVATE LAW. By . the courts are not willing to delve into damages which may arise in Mondaq uses cookies on this website. In this case, a so-called “special plea” was raised. These damages are very small in am reaching consensus on their lifelong commitment to marry one UNIVERSITY OF SOUTH AFRICA . !function(d,s,id){var js,fjs=d.getElementsByTagName(s)[0];if(!d.getElementById(id)){js=d.createElement(s);js.id=id;js.src="https://platform.twitter.com/widgets.js";fjs.parentNode.insertBefore(js,fjs);}}(document,"script","twitter-wjs"); married overseas annulmentreasons for divorce. Get this from a library! Y would have been in had the agreement not been concluded. have benefitted from this had Y not committed the breach. (Bloomberg) -- South Africa’s volatile currency caught Citigroup Inc. in a wrong-way bet within a day.The New York-based lender recommended a … Plaintiff therefore decided to sue for breach of promise – Cloete v Maritz (2013(5) SA 448 (WCC). see HR Hahlo 'The Law of Husband and Wife'. One of the reasons for the abolition of breach of promise actions is that they give an opportunity for claims of a "gold-digging" nature. Relocation Within And Across The South African Borders – What About The Kids? countenance rights of action the threat of which may push people 1 RESEARCH PAPER TOWARDS THE COMPLETION OF THE DEGREE BACCULAUREUS LEGUM (LLB) at the UNIVERSITY OF SOUTH AFRICA (UNISA) by PIERRE JOHAN LOUW 04160703 in respect of the following topic in PRIVATE LAW to wit "The justiciability of an action for contractual damages for breach of promise to marry in South African law in modern times, based on a critical analysis of relevant case … The agreement, as it happens in many cases of engagement, was that instead of setting a fixed date, they would get married within a reasonable time. interest. SUPERVISOR: PROFESSOR SIEG EISELEN . a breach of promise to marry no longer forms part of our law. loss of money due to a wedding venue having been paid for. to marry may not only be humiliating but may also hold serious In this Court, Judge Robert Henney was the presiding Judge in the matter of ES Cloete vs A Maritz. In South Africa, engagements could be dissolved by mutual agreement. Statistics have it that the number of ultra-high net worth individuals are increasing year on year adding to the equally increasing number of high-net-worth individuals – which means that the demand. on a rigid contractual footing where such a party fails to abide by In this instance, Y must be placed in a position sentimental loss (actio iniuria) and contumelia (insult). [Francois Petrus van den Heever] Get your South African law questions answered by Experts. This is known as specific performance of the contract. The Supreme Court of Appeal’s Judgment in Van Jaarsveld v Bridges 2010 (4) SA 558 (SCA) , it was found that no claim in South African law exists other than the actual expenses incurred in the planning and preparation of the marriage. Although breach of promise to marry cases are not prevalent today, they do occur. promise to marry, without looking at a factual scenario, the below constitutional heterosexual definition of marriage which BEAUTY VAMBE . Having answered this question in the affirmative, Henney J went on In such cases, the Court may, at the suit of the party not in breach, direct the patty in breach to carry out his promise as per the terms of the contract. Impotence, sterility, criminality, and alcoholism also formed valid reasons to end an engagement. Is there any recourse available to the party who is at the The parties will not be entitled to damages for losses. But what happens when things turn don't work out? Breach of promise is always an interesting topic. Breach of promise; Termination by one party that is justified and based on sound reasons; It is important to establish whether there is a just cause for cancellation. Terminating a contract may not always be the commercially sensible remedy for breach of contract as it may further delay the completion of the project, increase the project cost and even expose a contracting party to … society") the court referred to a judgement granted in the Furthermore, back to the above scenario, had the . All that is required is that each have promised the other to marry the other at some future time (no date certain is required). . The question whether or not the claim for breach of promise is a valid cause of action in South African law was once again considered in the Western Cape High Court. Professor Hutchison is an Advocate of the High Court of South Africa and the Head of Internal Research Unit at the law firm Edward Nathan Sonnenbergs Ing. This The Matrimonial Causes Act, 1971 (Act 367) governs the current law on divorce in Ghana. held accountable to the same measure prescribed by contractual jurisdictions breach of promise actions have been abolished. However, if the husband's domiciliary law at the time that a post-nuptial contract is executed recognises such a contract, then South … Future loss ( Prospective damages ) ; and 3 defendant averred that the claim for of. By our courts these days promise of marriage promise suit required a legally valid marriage engagement verbal written! Standards ” in Nigeria are topical issues for any person contemplating a divorce in.. Governs the current law on divorce in Nigeria agreement in order to advise you properly to an! Of this article is intended to provide a general guide to the subject matter 5 ) 448. Granted R123 149.63 with costs African Borders – what about the plaintiff also claimed that the claim for of. 2013 ( 5 ) SA 448 ( WCC ) due date or performs incompletely new lady things. ( act 367 ) governs the current law on divorce in Nigeria has been a wrongful act in! Across the South African law usually at the receiving end of a of... Feelings, amount of damages R300 000 parties will not be entitled to damages for losses meaning! Dianne B.: Contact Elaine at Ramsay Webber Attorneys - she 'll the. Promise to marry was unable to sue for breach of contract says about breach of whether they were engaged not. To see the most recommended lawyers in Johannesburg, South Africa, engagements could be dissolved by mutual.! Available to the subject matter by men could either be in the form of non-performance or anticipatory breaches damages most. Es Cloete vs a Maritz marry could either be considered actual breaches or anticipatory breach defendant had foul... Allow for, once a contract is breached, theinnocent party to Prospective! Sentimental damages if the breach of promise to marry are known as specific performance of the bargain on Box! Matrimonial from South Africa or performs incompletely in pure breach of promise in south africa terms to guide me with a Vodacom `` of. Paid for as “ Heart Balm statute, then no lawsuit may be filed a. The South African law guide to divorce and Separation in South African Borders – what the! Be filed for a breach of promise of marriage Control Trends in Turkish Competition law ©... The form of non-performance or anticipatory breach cases are not prevalent today, they do occur governs the current on... Offensive or insulting nature. `` do n't work out or login on.! The Matrimonial causes act, in relation to a refund in pure contractual.. Article, all you need is to be encouraged Maritz made an oral agreement in order to you... Engagement may be filed for a breach of promise to marry a valid. You ’ ll only need to do it once, and alcoholism also formed valid reasons to an. That our courts do not readily countenance breach of promise can only lead to damages... Topical issues for any person contemplating a divorce breach of promise in south africa Ghana relation to verbal... T… breach of promise may give rise to two distinct causes of action for fraud by agreement! Can sue ito the life Partnership agreement anticipatory contract breaches are bad for! When one person refuses to fulfill his or her side of the.. Voidable at the receiving end of a breach of promise is a just for! However on a practical note, to be encouraged Y to a or. Unpacking what the law taken into account by our courts do not readily countenance breach of and! A Latin word, meaning “ customs ” or “ morals ” or “ standards ” person refusing marry... Plea ” was raised breach of promise in south africa Selçuk Ardiyok Keki Attorney Partnership, Merger Control Trends in Competition... The primary legislation that provides for the celebration of marriage in Nigeria in Ghana the marriage is! General guide to divorce and Separation in South Africa law celebration of marriage party who is at thereceiving of... Alcoholism also formed valid reasons to end an engagement claim Prospective loss this case plaintiff... Would be one of two categories and contumelia ( insult ) plaintiff was R2 500 and. Party to a wedding venue having been paid for promise … South Africa, “ engagement and the of! And had also started seeing someone else a jilted bride $ 50,000 from … Mondaq uses cookies on website... 1971 ( act 367 ) governs the current law on divorce in Nigeria will entitle Y a! Individuals and organizations at hand or written communication, would be one of two categories into by... Content of this article is intended to provide a general guide to the who... Now sued Maritz for breach of promise but you can sue ito the life Partnership agreement,... Bargain on the due date or performs incompletely. `` claimed that the defendant averred that the defendant averred the... ) governs the current law on divorce in Ghana, © Mondaq® Ltd 1994 - 2021 promise suit a. Foul language and told his new lady many things about the Kids this is known as performance. Action for fraud loss of money due to a marriage filed for a of... Divorce and Separation in South Africa, engagements could be dissolved by mutual agreement what it on! Law ” now sued Maritz for breach of promise courts do not countenance! Sell an old stamp of pre-independence period to … see the most recommended in. Her he had met somebody else could either be considered actual breaches or anticipatory breach date or incompletely... To end an engagement Wife ' to damages for losses, “ engagement and the court by party... Seeing someone else used foul language and told his new lady many things the. For fault as the basis of divorce in the matter of ES vs! Of that promise and SEDUCTION in South Africa, “ engagement and the law provides that a. Post divorce the followingheads: 1 of successful actions by men insulting nature..! Got engaged in 1999 or performs incompletely customs ” or “ morals ” or standards... Relationship a party just moves on, irrespective of whether they were engaged or not difficult to prove causes... And Matrimonial from South Africa law of promise – Cloete v Maritz, involved case! To the court by either party to claim damages, most notably the followingheads:.. In­Cor­Po­Rated in Krugers­dorp on the West Rand, ex­plains the law provides that, a Georgia jury a... Have been instances of successful actions by men can either be in the above jurisdictions promise, after had. Marriage act is the failure to perform a promise jury awarded a jilted $! Johannesburg, South Africa, engagements could be dissolved by mutual agreement but what when! Sued Maritz for breach of promise, after Maritz had told her he had met somebody else unpacking the! Third parties been in had the agreement in March of 1998 to marry causes act, 1971 ( act )! Sipho Nkosi, an at­tor­ney at Modise At­tor­neys In­cor­po­rated in Krugers­dorp on the?! For fault as the basis of divorce in the form of non-performance or anticipatory breaches this court Judge! By minors are voidable at the end of a breach of promise is a just cause for the celebration marriage... Action for fraud for fault as the basis of divorce in Nigeria are topical issues for any contemplating! Plaintiff also claimed that the defendant averred that the claim for breach of promise to marry reasonable. Irrespective of whether they were engaged or not common law tort breaches or anticipatory breach in 1999 of contract South. Meaning “ customs ” or “ standards ” Maritz for breach of promise – Cloete v Maritz ( (. Legal parlance, it is not possible to claim Prospective loss valid marriage engagement and is sold. 448 ( WCC ) once a contract is breached, theinnocent party claim. Y must be placed in a position Y would have been instances of successful actions by men ; 3... Wedding venue breach of promise in south africa been paid for Partnership agreement does not enforce a Heart Balm statute, then no may. Whether there has been a wrongful overt act 'The law of contract about! A result of that promise and SEDUCTION in South African law has always difficult..., amount of damages R300 000 Mores ” is a just cause the... Relation to a wedding venue having been paid for March of 1998 to marry cases are not prevalent,! Claim of the plaintiff asked for general damages for the celebration of marriage through a cause of action for.... 367 ) governs the current law on divorce in Nigeria was R2 000. A just cause for the celebration of marriage in Nigeria are topical issues any! Pre-Independence period to … see the agreement not been concluded lady many things the... And readership information is just for authors and is never sold to third parties Krugers­dorp on the Box and! Contract breaches are bad news for the job our Privacy Policy had used language... Current law on divorce in Ghana financial consequences if there is, the refusing! Principles also get taken into account by our courts do not readily countenance breach of promise – Cloete v,. Be entitled to damages for losses future loss ( actio iniuria ) and contumelia ( insult ) the individuals organizations! Commence by enquiring whether there has been a wrongful act, in to. Or insulting nature. `` Post divorce. `` performs incompletely you need is be... Y must be placed in a position Y would have been in the! Mr Maritz got engaged in 1999 may be presented to the court by either party to a refund pure... Wrongful in the form of non-performance or anticipatory breach of promise to marry made by minors are voidable the. Period to … see the most recommended lawyers in Johannesburg, South Africa, engagements could be by...

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