Cross-examination rights may be closed after repeated default where adjournments are abused and trial progress is obstructed.

Repeated adjournments and non-appearance can justify closing a party's right to cross-examine when that party has been given multiple last opportunities, including costs, yet still fails to proceed. The Court treated cross-examination as a procedural right that is not unfettered and held that parties must cooperate in the progress of trial rather than keep proceedings pending at their leisure. On the record, the trial court's closure of the defendant's right to cross-examine was supported, and the High Court's affirmation was upheld.

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Issues: Whether the order closing the defendant's right to cross-examine the plaintiff's witness for repeated non-appearance and repeated adjournments was justified.

Analysis: The right of cross-examination was not a matter of unfettered entitlement where the defendant had been granted numerous adjournments over several years, had already been given repeated last opportunities with costs, and still failed to cross-examine the witness. Repeated adjournments were characterised as an abuse of procedure and a threat to the effective administration of justice. The Court emphasised that parties must cooperate in the progress of trial and cannot keep the matter pending at their leisure. In such circumstances, the trial court's decision to close the right to cross-examine was fully supported by the record and the High Court was right in affirming it.

Conclusion: The closure of the defendant's right to cross-examine was upheld.

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