The City of Johannesburg Metropolitan Municipality v The Chairman of the Valuation Appeal Board for the City of Johannesburg and Another

The City of Johannesburg adopted a rates policy and valuation roll under the Local Government: Municipal Property Rates Act 6 of 2004. Connaught Properties (Pty) Ltd owned a property, Park Mews in Hillbrow, zoned ‘Residential A’ with permitted use for shops and offices on the ground floor and residential apartments above. The municipal valuer categorised the property as ‘property used for multiple purposes’ but did not apportion its market value between business and residential uses, instead applying the higher business rate to the entire value. Connaught objected, arguing that the market value should be apportioned between residential and business uses under s 9 of the Act. The municipal valuer rejected the objection, but on appeal the Valuation Appeal Board upheld it and ordered an apportionment. The City sought to review that decision in the High Court, which dismissed the application, leading to this appeal.

The appeal was dismissed with costs; the decision of the Valuation Appeal Board requiring apportionment of market value between different uses was upheld.

The case clarifies the interpretation of sections 8 and 9 of the Municipal Property Rates Act and confirms that municipal valuers must apportion market value for multiple-use properties in the valuation roll. It reinforces the independence and central role of municipal valuers and protects ratepayers from municipalities applying higher tariffs to entire properties without proper valuation. The judgment is an important authority on municipal rating, valuation procedures, and administrative fairness.