High Court of South Africa Free State, Bloemfontein

The Free State Division of the High Court of South Africa (previously named the Orange Free State Provincial Division and the Free State High Court, and commonly known as the Bloemfontein High Court is a superior court of law with general jurisdiction over the Free state province of South Africa. The division sits at  Bloemfontein.

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168 judgments
Citation
Judgment date
December 2022
Interim maintenance orders against a trustee discharged where material disputes of fact require oral evidence; each party bears own costs.
Trusts – testamentary trust – beneficiaries seeking maintenance from trustee; urgent motion proceedings – suitability where material disputes of fact exist – Plascon‑Evans rule; Uniform Rule 41A non‑compliance – condonation in appropriate urgent cases; investment held by trustee for trust’s benefit – not ipso facto misconduct; maintenance relief may be pursued in Maintenance Court.
29 December 2022
The defendant cannot rely on disclaimers to avoid liability for gross negligence causing the applicant’s injury.
Delict – occupier’s liability and negligence – gross negligence/recklessness where an uncordoned man‑made hole caused injury; contractual disclaimers/exclusion clauses – visibility, assent and CPA formalities; public policy limit on exclusion of liability for gross negligence; adverse inference from defendant’s silence.
23 December 2022
Whether contractual restraints and confidentiality are enforceable where joint suspensive conditions, including agreed payment and employment, were not fulfilled.
Sale of business – suspensive conditions – joint suspensive conditions (employment/remuneration and insurance) prevent contract becoming perfecta; simulated transaction – nominal purchase price disguised true price (R100 vs R7.8m); reciprocal obligations and breach – purchaser’s failure to pay bars enforcement of restraint of trade, confidentiality and goodwill; Plascon‑Evans rule applied to affidavits; mootness of expired restraint.
22 December 2022
Urgency not established: delay and unsubstantiated expert report defeat application for interim supervised sleepover contact.
Family law – Contact and interim relief – Urgency and self-created urgency – Applicant failed to explain three‑month delay; psychologist's report recommended family advocate investigation before sleepover contact; supplementary expert note unsubstantiated; child's wishes relevant but not determinative; best interests paramount.
20 December 2022
Prescription claim failed due to alleged permission, but servitude by necessity granted and registration ordered.
Servitudes – acquisitive prescription under s 6 Prescription Act – requirement nec vi, nec clam, nec precario – effect of perfunctory permission (precarium). Motion proceedings – Plascon-Evans rule: disputed facts on affidavits must be accepted where not untenable. Servitude by necessity – landlocked dominant tenement; shortest route and least damage principles; equitable balance. Registration and compensation – court may authorize registration and accept tendered compensation for expropriation-like interference
15 December 2022
A time‑limited interim interdict became moot; confirmation refused and litigating parties ordered to bear their own costs.
Interim interdict — Rule Nisi confirmation — Mootness where time‑limited order expired; Court discretion to refuse confirmation of moot orders; Application of factors in Normandien Farms to decide whether to entertain moot matters; Costs — Biowatch principle: parties defending constitutional rights in good faith should not be penalised; where matter moot and both sides acted in good faith each party to bear own costs.
14 December 2022
Leave to appeal refused because the applicants lacked reasonable prospects of success; costs awarded against applicants.
Civil procedure – leave to appeal – application under Rule 16.5 – requirement of reasonable prospects of success – dismissal for lack of prospects; costs awarded.
14 December 2022
Application for leave to appeal dismissed; brief late Heads of Argument condoned but applicant ordered to pay costs.
Appeal procedure – application for leave to appeal – assessment of reasonable prospects of success and compelling reasons to grant leave. Civil procedure – condonation – brief four‑day delay in filing Heads of Argument – no prejudice, condoned. Judicial conduct – allegation of judge’s close relationship with third party – recusal not warranted where allegation lacks substance Costs – applicant ordered to pay costs of condonation and of the application for leave to appeal
14 December 2022
A section 317 special entry is inappropriate where the alleged irregularity appears on the record and particulars are sufficient.
Criminal procedure – section 317(1) special entry – procedure reserved for irregularities not appearing on record; grounds to refuse: not bona fide, frivolous/absurd, abuse of process – where irregularity is on record raise on appeal – adequacy of indictment and particulars to prepare for trial.
14 December 2022
Court found arrest and prosecution supported by reasonable grounds; plaintiff failed to prove unlawful arrest or malicious prosecution.
Criminal procedure – Arrest without warrant – s 40(1)(b) CPA – objective test of reasonable suspicion; possession of complainant's statement and J88 report can constitute reasonable grounds. Criminal procedure – Detention consequent on lawful arrest Delict – Malicious prosecution – requirements: institution of proceedings, absence of reasonable and probable cause, malice, and failure of prosecution; onus on plaintiff to prove lack of cause and malice. Prosecutorial discretion – exercised bona fide where prosecutor applies mind to police docket and reasonable possibility of conviction exists
13 December 2022
Reported
Court dismissed appeal: magistrate's interventions did not render trial unfair; child witnesses' evidence credible; sentences confirmed.
Criminal law — Evaluation of child witness evidence; judicial intervention and impartiality — when questioning by presiding officer vitiates trial; contradictions between police statements and viva voce evidence; credibility and probabilities; sentencing for sexual offences against minors (life imprisonment).
13 December 2022
Court confirmed removal of child to protect him, ordered supervised contact and appointed curator ad litem with rehabilitation conditions.
Children — Children's Act — child in need of care and protection — removal from caregiver justified where credible evidence of neglect, developmental neglect and exposure to harm — Family Advocate report relevant but not binding — appointment of curator ad litem — supervised contact and rehabilitation conditions for restoration of care.
7 December 2022
An interim payment certificate under a construction contract is a liquid document enforceable absent limited grounds of attack.
Construction law — Interim payment certificate under JBCC — Certificate treated as liquid document/acknowledgement of debt — Limited grounds to attack liquidity (fraud, collusion, agent exceeding authority) — CPAP base month fixed by contract — Court may order payment despite internal budgetary/treasury processes or absence of final account.
7 December 2022
Unlawful municipal manager appointment; municipality ordered to pay costs and council must consider recovering costs from responsible office-bearers.
Local government – Appointment of municipal manager – Procedural and substantive irregularities – Speaker and Mayor’s conduct held unlawful, deliberate and grossly negligent – Interim interdict and referral back to council – Costs ordered against municipality; council to investigate recovery from office-bearers under s176(2) MFMA – Compliance with court orders and accountability of councillors.
6 December 2022
Court awards limited (10%) diminution for future loss of earnings; capital award R1,318,266.40 after interim payment.
Delict — Motor vehicle collision — Future loss of earnings and earning capacity — Causal link between injury and termination of prior employment — Evaluation and weight of expert reports — Actuarial computation and judicial discretion on contingencies — Deduction of interim payment.
5 December 2022
Contract void for lack of consensus on inventory; rectification and specific performance refused; cancellation and restitution ordered.
Sale of business — rectification — parol/integration rule — unsigned annexure — absence of consensus (ad idem) on merx — calculation-dependent obligations — contract void for vagueness/mutual mistake — cancellation and restitution ordered.
2 December 2022
Review to compel registration dismissed as time-barred under PAJA due to unreasonable delay and no condonation.
Administrative law — Promotion of Administrative Justice Act (PAJA) — timing of review proceedings — section 7(1) 180-day limit begins when person becomes aware of administrative action — absence of section 9 condonation/extension fatal — review for failure to register applicants on provincial transport register time-barred.
2 December 2022
High Court dismisses application to remove prosecutor: wrong forum and allegations unproven, costs on attorney-and-client scale.
Criminal procedure — Recusal of prosecutor — Proper forum is trial court; motion to High Court inappropriate where trials are advanced — Applicant must prove substantive unfairness or bias; mere allegations unsubstantiated on papers insufficient — Motion proceedings: Plascon‑Evans principle applies — Abuse of process and punitive costs where allegations are spurious and delay prejudicial.
2 December 2022
Applicant granted pendente lite maintenance, medical aid retention, vehicle use, cell-phone costs and legal-costs contribution.
Rule 43 – spousal maintenance pendente lite; antenuptial agreement waiving post-divorce maintenance does not necessarily bar interim maintenance; assessment by marital standard of living, applicant’s needs and respondent’s means; ancillary relief (medical aid, vehicle, cell phone, legal costs); exclusion of vague or unsupported claims.
2 December 2022
Applicant awarded R35,100 monthly pendente lite maintenance, medical aid retention, vehicle use, cell phone payments and R10,000 toward legal costs.
Family law – Rule 43 – spousal maintenance pendente lite – entitlement depends on marital standard of living, applicant’s reasonable needs and respondent’s capacity to pay; antenuptial waiver of post‑divorce maintenance does not necessarily preclude pendente lite relief Maintenance – quantum – court may allow periodic payments based on a reasonable budget and reject unproven or excessive claims (relocation, gardener, vague allowances) Orders – retention on medical aid, vehicle use, cell phone costs and contribution to legal costs may be appropriate pendente lite relief
2 December 2022
November 2022
Whether the taxing master was clearly wrong to depart from the tariff when taxing attorney-and-own-client costs; court held he was not.
Costs — Taxation and review — Whether taxing master properly exercised discretion to depart from tariff when taxing attorney-and-own-client bills — Requirement that review court be satisfied taxing master was 'clearly wrong' before interference — Penal costs de bonis propriis to prevent burden on insolvent estate.
30 November 2022
A taxing master’s discretionary departure from the tariff was upheld where an abortive urgent application and attorney misconduct justified attorney-and-own-client indemnification.
Costs — Taxation — Attorney-and-own-client scale — Taxing Master's discretion to depart from tariff in extraordinary/exceptional cases — Review standard: Taxing Master "clearly wrong" — Conduct of attorney and abortive urgent application as justifying departure from tariff.
30 November 2022
Eviction set aside where estate misrepresentation and long occupation by vulnerable occupiers made eviction not just and equitable.
PIE Act – eviction – requirement to show owner status, unlawful occupation and that eviction is just and equitable – consideration of duration of occupation and vulnerability (disabled occupier) Succession/Administration of Estates – misrepresentation of marital status when reporting death – effect on validity of alienation by estate representatives. Property law – RDP/housing subsidy property – rights of surviving spouse in community of property and intestate succession
30 November 2022
The applicant failed to prove exceptional circumstances for bail; the magistrate’s refusal was upheld.
Criminal procedure – Bail – Schedule 6 sexual offences – Exceptional circumstances required for release – Onus on accused to prove probable acquittal – Credibility and reliability assessments for trial, not bail – Court may consider propensity, risk of evasion and witness interference – Allegations of investigatory misconduct and judicial bias must be substantiated.
30 November 2022
Applicants entitled to interdict respondents from operating a frail-care business on residentially zoned property; pending rezoning is no defence.
Town planning and zoning – enforcement of zoning scheme – unlawful commercial use of residentially zoned property – entitlement to final interdict. Civil procedure – non-joinder – joinder required only where direct substantial interest may be prejudiced PIE Act – not applicable where eviction is not sought and relief is only to restrain unlawful use. Locus standi – neighbouring owners entitled to enforce zoning scheme. Re-zoning application – pending application does not justify continued illegal use. Characterisation of activities – non-profit label does not preclude finding of business where operations have business attributes
28 November 2022
Material procedural irregularities in taxation justified setting aside the allocatur and referring the bill for re-taxation before a different taxing officer.
Civil procedure – Taxation of costs – Rule 70 and Rule 48 – procedural compliance with notice, inspection and certification requirements – requirement that taxing officer exercise discretion judicially and keep records when hearing evidence Review – grounds for setting aside taxed bill – reliance on another judge during taxation, lack of record, hearsay, conflict of interest, late filings, misinterpretation of court order Remedy – setting aside allocatur and referral for re-taxation before different taxing officer; no order as to costs given evidentiary uncertainty
28 November 2022
Reported
Conviction for armed robbery upheld: single-witness identification credible, alibi rejected, but trial conduct and unexplained sentence deviation criticised.
Criminal law – Robbery with aggravating circumstances – Identification evidence – single identifying witness; cautionary rule applied Evidence – Prior acquaintance, daylight, proximity, scuffle and corroboration can render single-witness identification reliable Procedure – Improper judicial conduct (excessive questioning, suggestion to change plea) may warrant reproach but does not necessarily vitiate trial fairness Sentence – Departure from prescribed minimum sentence requires recorded substantial and compelling reasons
25 November 2022
Appeal upheld and convictions set aside because absence of any trial record made rehearing impossible.
Criminal procedure – Missing or incomplete trial records – inability to rehear appeal where no transcript or notes exist – conviction set aside and substituted with acquittal. Evidence preservation – digital court recording system (DCRS) failures and custodial responsibilities of court officials and practitioners. Appeal procedure – consequences of delay in applying for leave to appeal and cautions against condonation as of right
25 November 2022
Condonation for late reply granted for attorney negligence; purported sale invalid because seller lacked title; appeal dismissed.
Civil procedure – condonation for late filing – five-day delay due to attorney’s negligence – good cause established. Motion proceedings – replying affidavit containing new material – respondent permitted to file triplication. Property law – alleged sale of land where seller lacked title – requirement of s2(1) Alienation of Land Act – sale unenforceable. Resolution of factual disputes on motion – Plascon-Evans / Wightman principles applied; disputes decided against applicant. Prescription and non-joinder issues relevant to relief for transfer of property
24 November 2022
Court ordered targeted Rule 35(3) discovery, including limited bank statements and specified WhatsApp messages, costs in the action.
Rule 35(3) discovery – relevance determined by pleadings – reluctance to go behind discovery affidavit unless probability of error – overbroad requests to be narrowed – non-existent or unavailable documents cannot be compelled – WhatsApp messages may be discoverable if limited to relevant content.
24 November 2022
Applicants failed to show a reasonable prospect of success on appeal from dismissal of their insurance indemnity claim; leave refused.
Application for leave to appeal — Superior Courts Act s17(1) — elevated test requiring prospect that another court would reasonably reach a different conclusion — insured’s duty of full disclosure — interpretation of insurance contract — no reasonable prospects shown; leave refused with costs.
22 November 2022
Administrative understatement penalties and criminal tax‑evasion prosecutions are distinct; their combination does not breach double jeopardy.
Tax law – Constitutional challenge to sections 222 and 235 TAA – Whether administrative understatement penalties and criminal tax‑evasion prosecution constitute double jeopardy. Criminal procedure – Double jeopardy (section 35(3)(m)) – distinction between administrative/regulatory penalties and criminal punishment. Civil procedure – Res judicata/issue estoppel – whether prior criminal plea hearing precludes constitutional challenge
21 November 2022
Whether an arbitration agreement can oust the maintenance court’s jurisdiction to enforce a maintenance order.
Arbitration Act s2(a) – exclusion of "matrimonial cause or matter incidental thereto"; enforcement of maintenance orders and arbitrability; kompetenz‑kompetenz – arbitrator’s competence to decide own jurisdiction; party autonomy to agree forum for disputes arising from settlement agreements.
17 November 2022
Applicant failed to prove Fidelity Fund paid defendant or that defendant misapplied funds; claim dismissed.
Fidelity Fund claims – proof of payment; mandate and disbursement – attorney duty to pay approved claimant; repudiation of claim by Fidelity Fund; insufficiency of plaintiff's evidence; Rule 13 indemnity dismissed.
17 November 2022
Court found serious cervical and back injuries, accepted expert evidence and applied the initial actuarial contingencies for loss of earnings.
Road Accident Fund – Quantum only – Serious cervical and thoracolumbar injuries (C1–C2 ligamentous instability; probable C2–C3 fractures) – expert evidence accepted – hospital records insufficient to rebut – contingencies in loss of earnings (actuarial calculation preferred to post-morbid 70% increase).
17 November 2022
Conviction set aside because the trial record is missing; re‑prosecution may follow under section 324(c).
Criminal procedure – missing trial record/transcripts – inability to reconstruct proceedings – absence constitutes technical irregularity – conviction and sentence set aside – matter referred to DPP for consideration under s324(c) of Criminal Procedure Act.
17 November 2022
Intervening negotiations severed causation between an attorney's advice and spoliation; attorney not personally liable for costs.
Spoliation – unlawful deprivation of possession – restoration of status quo and withdrawal of opposition Lien/retention – subcontractor’s right to retain premises for unpaid work. Attorney conduct – whether advice to client causing spoliation creates personal liability for costs de bonis propriis Causation – intervening events and correspondence breaking causal link between legal advice and subsequent unlawful act Costs – discretionary award where primary relief became moot; successful party entitled to costs for period of opposition
16 November 2022
Eviction refused pending a section 2 Conversion Act inquiry to determine the lawful owner of the erf.
Property/PIE — Eviction application dismissed where title dispute exists; Conversion of Certain Rights into Leasehold or Ownership Act s2 — Director-General must hold inquiry to determine rightful owner; Administrative law/PAJA — not every post-decisional act is reviewable; Conversion Act inquiry may be prerequisite to relief.
14 November 2022
Universal partnership creates personal claims but is not a defence to eviction of trust‑owned property; eviction granted with six months to vacate.
Property law; eviction under PIE s 4(7) — occupier in place for more than six months — just and equitable enquiry; Universal partnership — confers personal contractual rights, not real rights in third‑party owned property, and is not a defence to eviction by registered owners; Eviction relief — reasonable implementation period; sheriff and SAPS authorised; costs reserved to parties to bear own costs.
11 November 2022
Whether the applicant’s failure to complete required subcontracting information rendered its tender non‑responsive.
Procurement law; Preferential Procurement Regulations (2017) — subcontracting as pre-qualification requirement; responsiveness of tenders; requirement to complete returnable schedules; Plascon‑Evans rule; contractual requirement for written communications; review of tender award.
7 November 2022
Arrests based on uncorroborated oral information were unlawful; plaintiffs awarded damages for detention until first appearance.
Criminal procedure – s 40(1)(b) CPA – reasonable suspicion an objective test – arrests based on uncorroborated oral confession insufficient; police must investigate exculpatory explanations – detention authority flows from arrest and is exhausted at first court appearance – legal causation limits liability for continued judicial detention.
4 November 2022
On the papers the court found the vehicles were instrumentalities in organised diesel theft and ordered their forfeiture to the State.
POCA – forfeiture under s 50 – requirement to prove on a balance of probabilities that property is an instrumentality of a Schedule 1 offence. Preservation orders – ex parte disclosure obligations; return of property during investigation does not necessarily preclude preservation/forfeiture. Civil procedure – Plascon-Evans rule – rejection of palpably implausible or uncreditworthy versions on the papers. Constitutional law – proportionality and arbitrary deprivation of property; significant disproportionality standard considered
4 November 2022
Court upheld conviction, finding the complainant credible and the appellants' explanation inherently improbable.
Criminal law – robbery with aggravating circumstances; single-witness evidence – cautionary approach and sufficiency; identification – identity admitted and confirmed at parade; cross-examination on prior police statement – basis must be laid or evidence unreliable; appellate review – deference to trial court on credibility findings.
3 November 2022
Indictment and State particulars sufficiently informed accused; exhaustive evidentiary particulars not required pre‑trial.
Criminal procedure – s 87 Criminal Procedure Act – requests for further particulars; right to be informed of charge (s 35(3) Constitution); sufficiency of indictment and statement of facts; distinction between required particulars and evidentiary/inferential matters; charges: PFMA contravention, fraud and money‑laundering.
3 November 2022
Leave to appeal granted on both defences to avoid piecemeal adjudication; appeal directed to the Full Bench.
Appellate procedure — leave to appeal; Finality of orders — whether exception-based striking of defences is final and appealable; Avoidance of piecemeal adjudication — interest of justice; Appeal to Full Bench; Costs to follow appeal.
1 November 2022
Court applies 5%/32.5% contingency to applicant’s loss of income claim and refers actuarial recalculation for court order.
• Quantum – loss of earnings – contingency deductions for pre-morbid future loss; expert and actuarial evidence as guide to court discretion; appropriate percentage for young claimant with limited pre-accident experience but total post-accident unemployability. • Admitted liability – RAF Act claims; referral to actuary to compute amounts with ordered contingencies.
1 November 2022
October 2022
Reported
Whether a COIDA-based special plea should be separated under Rule 33(4) and how COIDA payments affect common-law damages.
Civil procedure – Rule 33(4) – separation of issues – convenience and expedition; piecemeal litigation to be avoided COIDA – s 36 – interaction between statutory compensation and common-law damages; "compensation paid" v "paid or payable"; recovery and set-off issues Whether an employee can elect to terminate COIDA benefits and claim full common-law damages from a third party Overlap of expert evidence and risk of duplicative trials and appeals militating against separation
31 October 2022
Court awards R700,000 pre-apportionment for general damages to deceased claimant’s estate, applying conservative transmissibility principles.
Personal injury – Quantification of general damages for deceased claimant; transmissibility of claim to estate (Nkala); conservative approach where award benefits heirs (Du Bois); reliance on medico-legal reports where defendant concedes; assessment guided by comparable awards.
31 October 2022
Whether a financier may vindicate and repossess movable assets from a company under business rescue.
Companies Act – business rescue – sections 133 and 134 moratorium on proceedings and protection of property in lawful possession; Instalment sale – ownership passes on payment per individual agreement; Interim interdict – prima facie right, balance of convenience, enforcement against assets in business rescue; Procedural points – jurisdiction, urgency, joinder, notice to creditors.
28 October 2022
Auction terms reserved seller discretion; no contract arose and urgent interdict dismissed with costs.
Auction law – conditions of sale – effect of a seller’s reserved right to confirm sale; highest bid may amount only to an option if seller’s confirmation is required. Contract law – pactum de contrahendo/option – requirement that underlying offer be capable of creating a valid contract; Brandt and Withok principles applied. Interim interdict – quasi‑vindicatory relief – limitations where no clear prima facie right exists and applicant’s conduct indicates acquiescence Urgency – self‑created delay defeats urgent relief. Res judicata / lis pendens – prior dismissal in magistrate’s court and pending appeal relevant to duplicative proceedings Costs – attorney‑and‑client and wasted costs awarded
27 October 2022