Moloi v Nkosi and Others (1713/2025) [2025] ZAFSHC 153 (15 May 2025): Customary Marriage Claims Undone by Motion Proceedings and the Plascon-Evans Rule.

Procedural Pitfalls: The Unsuitability of Motion Proceedings in Customary Marriage Disputes

The applicant’s decision to approach the court by way of motion proceedings was a central procedural miscalculation. In matters involving the existence of an alleged customary marriage—particularly where one party relies on oral tradition, undocumented rites, and competing affidavits from family members—proceeding by motion invites inevitable procedural limitations. As the court underscored, this case was saturated with material factual disputes, many of which were incapable of resolution on paper alone.

Once the respondents filed an answering affidavit denying key elements of the applicant’s claim—such as the payment of lobolo, the occurrence of traditional celebrations, and the existence of a marriage—the dispute transcended the realm of legal interpretation and entered that of contested fact. Despite this, the applicant did not seek a referral to oral evidence or a trial. On the contrary, she maintained during argument that proceeding on affidavit would suffice, even going so far as to deny the existence of genuine factual disputes. This procedural stance, while perhaps tactical, proved fatal.

The judgment observed that disputes concerning the validity of customary marriages, particularly those concluded before the enactment of the Recognition of Customary Marriages Act 120 of 1998, require careful evidentiary ventilation. Without the opportunity to cross-examine witnesses or assess credibility, the court was left to apply the Plascon-Evans Paints v Van Riebeeck Paints 1984 (3) SA 623 (A) rule, effectively favouring the respondent’s version unless it was shown to be inherently untenable. The court further noted that customary marriage disputes have, in multiple decisions, been declared unsuitable for resolution through motion proceedings—yet this procedural caution was not heeded by the applicant.

This misstep was compounded by the applicant’s own acknowledgement that the lobolo letter had been lost and that no documentary registration of the alleged marriage existed. These evidentiary deficiencies, coupled with the applicant’s choice of forum, prevented the court from making any meaningful findings on whether a valid customary marriage had existed. In effect, the applicant bore the burden of proof but opted for a mechanism ill-suited to discharging it.

Written by Bertus Preller, a Family Law and Divorce Law attorney and Mediator at Maurice Phillips Wisenberg in Cape Town and founder of iDivorce and iANC. A blog, managed by SplashLaw, for more information on Family Law read more here.

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