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.

1,117 judgments
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1,117 judgments
Citation
Judgment date
February 2026
Leave to appeal and admission of fresh Task Team report denied; applicant failed to show reasonable prospects or exceptional circumstances.
Civil forfeiture and appeals – leave to appeal under s 17(1)(a) Superior Courts Act – standard: reasonable prospects or other compelling reasons; New evidence on appeal – requirements: adequate explanation for lateness, prima facie likelihood of truth, materiality; Proceeds of unlawful activities – applicant must establish unlawfulness; municipal Task Team report held not to establish fraud or exceptional circumstances.
19 February 2026
An LPC dismissal bars re‑litigation of the same misconduct complaint in court; review of the LPC is the proper remedy.
Legal Practice Act s44 – misconduct complaints – finality of LPC investigatory and appeal processes – dissatisfied complainant must review LPC decision rather than re‑litigate same complaint in court; PAIA – access to police/prosecution records – failure to comply with PAIA requirements; abuse of court process – unsubstantiated, vague pleadings.
18 February 2026
Unlawful extradition alone does not automatically oust trial court jurisdiction; remaining jurisdictional challenges dismissed.
Criminal procedure — special plea of no jurisdiction — effect of unlawful extradition on domestic jurisdiction — evidentiary burden on prosecution to prove jurisdiction beyond reasonable doubt — alleged misrepresentations to foreign authorities (probable cause, fugitive status, flight risk, syndicate involvement) — reliance on foreign extradition court findings and forensic audit evidence.
18 February 2026
Minor pedestrian with mild TBI, orthopaedic injuries and scarring awarded R600,000 general damages; RAF liable for 90%.
Road Accident Fund – general damages – quantum for minor pedestrian with mild traumatic brain injury, united clavicle and humerus fractures, persistent headaches and forehead scarring – comparative awards as guidance – court’s discretion in assessing fair compensation.
18 February 2026
Plaintiff awarded R1.9m for loss of earning capacity after defendant's default; general damages separated for later trial.
Road Accident Fund – quantum – loss of earning capacity – passenger injured in collision – orbital/zygomatic and cranial fractures – default judgment and admission of expert reports (rule 38(2)) – reliance on pleaded claim where particulars not amended – separation of general damages (rule 33(4)) – costs including expert fees.
17 February 2026
A suspended attorney lacking a Fidelity Fund certificate may not represent his firm; courts may vary orders to correct patent errors.
Legal Practice Act s84 – Fidelity Fund certificate – suspended attorney may not practise or handle client funds; Representation of juristic persons – director cannot ordinarily represent company in court absent exceptional leave; Uniform Rule 42(1)(b) – variation or rescission permitted to correct patent errors in orders; Motion courts – variation to align court orders with underlying settlement agreements; Joinder – not required where variation corrects patent error and director lacks substantial interest.
13 February 2026
Leave to appeal dismissed where applicant failed to show bias, clear error on credibility findings, or prospects of success.
Leave to appeal — prospects of success — judicial bias — review v. appeal — credibility findings — probative value of ‘Letter of Completion’ — allegation of alteration to record not pursued
13 February 2026
Leave to appeal refused: failure to join and to serve additional trustees rendered amendment fatally defective; appeal lacked reasonable prospects.
Civil procedure — Trusts — Trusts lack juristic personality; trustees must be cited nomine officii — Joinder of all trustees required absent express authority — Amendment to add trustees requires service on trustees to be joined — Non-joinder/service may render proceedings fatally defective — Appealability of refusal to amend when final in effect.
11 February 2026
A stay of execution was confirmed for an attached refuse truck despite unauthorised company representation, due to public interest.
Uniform Rules; Legal Practice Act s33(1); unauthorised representation of a company; leave for non‑professional representation; stay of execution; public interest; essential service vehicle (refuse truck).
9 February 2026
Court set aside an association’s refusal to hold disciplinary proceedings and ordered a hearing with costs against the association.
Administrative law – Review of association’s internal disciplinary decision – Whether refusal to institute disciplinary proceedings was proper – Disciplinary code procedures and role of legal representative – Remedy where no internal appeal exists – Costs where opposition withdrawn.
5 February 2026
Appellate court ordered partial concurrency under s 280 to avoid a disproportionately crushing cumulative sentence for the appellant.
Criminal procedure — Sentence — Appellate interference — Limits of interference for material misdirection or disturbingly inappropriate sentence — Cumulative effect of sentences — Proportionality — Partial concurrency under s 280 Criminal Procedure Act 51 of 1977 to ameliorate unduly crushing aggregate sentence — Kidnapping, murder, escape from lawful custody — Antecedents and absence of remorse as aggravating factors.
3 February 2026
Condonation under s3 Act refused for excessive unexplained delay, weak prospects of success, and prejudice to respondents.
Condonation — s 3 Institution of Proceedings Against Certain Organs of State Act 40/2002 — requirements for condonation: full and reasonable explanation, prospects of success, and prejudice to organ of state — onus on applicant to provide detailed, evidence-based reasons for delay — excessive unexplained delay and weak merits justify refusal.
2 February 2026
Leave to appeal refused: no reasonable prospects of success under s17(1) regarding interdict and contractual/electricity disputes.
Leave to appeal – section 17(1) Superior Courts Act – reasonable prospects of success – interdictual relief – contractual rights under User Agreement – notarial deed void for non-registration – alternative remedies (Eskom) – inadmissible new evidence on leave application.
2 February 2026
January 2026
General damages postponed because the respondent neither accepted nor rejected the RAF4; expert-report conflicts delay other awards.
Motor-vehicle collision — RAF concedes merits — Rule 38(2) affidavits admitted for quantum — s 17(1A) and Regulation 3(3)(dA): RAF must accept/reject RAF4 within prescribed period — court lacks jurisdiction to award non-pecuniary loss where RAF neither accepted nor rejected RAF4 — expert-report discrepancies (occupational therapist v industrial psychologist) undermine actuarial loss-of-earnings and future-medical projections — s 17(4)(a) undertaking deferred.
30 January 2026
Court balanced Rule 21(2) compliance against fairness, ordering particulars within ten days and authorising strike‑out application if respondent defaults.
Civil procedure – Uniform Rule 21(2) – application to compel further particulars – court’s discretion to balance procedural compliance against fairness and proportionality – prior procedural inactivity and timing during festive recess relevant to relief and costs.
30 January 2026
The appellant's sentence for fraud was reduced after the trial court overemphasised seriousness and insufficiently considered mercy.
Criminal law – sentence – appellate interference with sentencing discretion (Malgas) – balancing Zinn factors including mercy (Rabie) – fraud exploiting vulnerability – first offender, prospects of rehabilitation – reduction and ante-dating of sentence.
29 January 2026
Seizure unlawful where police lacked specific, articulable facts to establish reasonable suspicion.
Criminal procedure – seizure of suspected stolen property – reasonable suspicion must be specific and articulable, not a hunch; evidentiary requirement for stakeholder identification; urgency and interim interdicts against the state (s 35 General Law Amendment Act).
28 January 2026
A rule 30A striking‑out application failed: rule 30A prescribes a 10‑day notice but no further fixed filing timeframe; merits of rescission timing remain for hearing.
Civil procedure – Uniform Rules of Court – rule 30A enforcement procedure – 10‑day notice to rectify; no additional fixed timeframe for launching striking‑out application. Procedural compliance – rule 6(5)(a) and 6(5)(b)(iii) – notice of motion requirements and filing of notice to oppose. Rescission – interplay of rule 31(2)(b) and rule 42(1)(a) – substantive time‑bar issues to be decided on rescission merits. Distinction between rule 30A and rule 30 (irregular steps). Abuse of process and delay considered but not decisive for striking out.
26 January 2026
Shopkeeper liable for 70% of slip‑and‑fall damages where ramp was too steep, wet and lacked safety features.
Delict — premises liability; duty of care of shopkeeper to customers at entrance ramp — non‑compliant ramp gradient (SANS 400 D), absence of handrails and anti‑slip measures — causation of slip‑and‑fall injury — contributory negligence and apportionment — admissibility and weight of expert slip‑resistance testing.
22 January 2026
Plaintiff proved engineering-career future loss but failed to prove projected professional rugby career; defendant liable for 90%.
Road Accident Fund — quantum of damages — proof of future loss of earning capacity — contested professional-sport career prospect vs engineering-career scenario — actuarial and industrial-psychology evidence; apportionment 90/10; s 17(4)(a) undertaking; costs.
22 January 2026
Court refused interim interdict restraining trustees’ transfers, finding no clear right and sales valid under insolvency authorisations.
Insolvency law — interim interdict pendente lite restraining trustees from transferring estate assets — requirements for interlocutory interdict; insolvency practice — trustee powers to sell immovable property prior to second meeting where Master gives permission (s 18(3) read with s 80(bis)); auction law — compliance with auction rules and Consumer Protection Act regulations governing deposits, confirmation period and commissions; locus standi of insolvent/reversionary interests; late affidavits (pro non scripto); alleged conflict of interest under Legal Practice Council rule 58.8.
22 January 2026
Applicants failed to show a right to interdict trustees from transferring insolvent estates' property pending a Master's inquiry.
Insolvency law – interim interdict standards – section 152 Master’s powers – sale of assets prior to second meeting (s 18(3)/s 80(bis)/s 82) – auction rules and Consumer Protection Act regulations – trustees’ fiduciary duties and creditors’ directions – locus standi – conflict of interest for practitioners.
22 January 2026
Court enforces personal guarantees and settlement agreement; trust resolution authorising guarantee held valid under the trust deed.
Trust law – interpretation of trust deed – written resolutions and round‑robin clauses (clause 8.5) – unanimous written approval for guarantees (clause 8.6.4) – enforceability of guarantees; Contract/public policy – Barkhuizen approach to contractual fairness and enforcement; Credibility and summary judgment – failure to raise bona fide factual dispute.
22 January 2026
Court made settlement an order under Rule 41, finding no duress and no breach of s35(12) of the Administration of Estates Act.
Civil procedure – Uniform Rule 41 – settlement reduced to writing and unenforced – application for judgment in terms thereof; Contract law – undue influence and duress – threat to sue/continue litigation not contra bonos mores; Administration of Estates Act s35(12) – distinction between judgment recording a claim and execution against estate; Procedural duty – dominus litis to cite/serve Master; Costs – allocation and scales.
22 January 2026
22 January 2026
Fraudulent transfers after a lapsed suspensive sale do not pass ownership; transfers set aside and title restored to the victim.
Transfer of immovable property — suspensive condition lapses if not fulfilled — abstract theory requires registration plus valid real agreement — fraud or forged/defective documents prevent ownership passing despite registration — nemo plus iuris: one cannot transfer better title than one has — fraudulent back-to-back transfers set aside; property restored to original owner.
19 January 2026
Whether termination without prior demand where no time fixed constitutes repudiation and warrants specific performance.
Urgent application – Rule 6(12) – urgency and absence of substantial redress; Contract law – mora ex persona – where no time fixed interpellatio required; Repudiation – premature termination without demand; Specific performance – ordered where termination invalid and damages inadequate; Arbitration clause – does not oust court’s jurisdiction for urgent relief.
19 January 2026
Assessment of future loss of earnings after childhood brain injury; late plea‑amendment/postponement refused, expert reports admitted.
Damages — motor vehicle accident — future loss of earnings; admission of expert affidavits and medico‑legal reports (Rule 38(2) and s3(1) LOEAA); refusal of late application to amend plea/postpone; assessment and application of contingencies in actuarial calculation.
19 January 2026
Court awarded R1,100,000 general damages to applicant after accepting unchallenged expert evidence of multiple serious injuries.
Road Accident Fund claim – determination of general damages – acceptance and weight of unchallenged expert reports – assessment of non-patrimonial loss (brain injury, orthopaedic injury, sensorineural hearing loss, neurogenic bladder) – judicial discretion in quantum – costs and interest provisions.
16 January 2026
Provisional liquidation granted where statutory demand was served, payment-arrangement request did not show bona fide dispute, and lis pendens did not apply.
Companies Act — Provisional liquidation — s 344–345 Old Act/schedule 5 of New Act — statutory letter of demand (s 69(1)(a)) — bona fide dispute requirement — lis pendens/lis alibi pendens — amendment of citation following conversion from CC to Pty Ltd — costs in liquidation.
16 January 2026
Head-on collision caused by insured crossing centre line; plaintiff partly negligent, damages apportioned 70/30 in plaintiff's favour.
Road Accident Fund liability – head-on collision – vehicle crossing centre line – contributory negligence for failure to keep proper lookout – apportionment of damages 70/30 – caution in undefended RAF matters.
15 January 2026
Court varied its prior judgment mero motu to correct omission and awarded costs, including counsel on scale B.
Civil procedure – variation of judgment under Uniform Rule 42(1)(b) – mero motu correction of accessory or consequential omissions – costs follow the result – Firestone principle applied.
14 January 2026
Appellant’s condonation for a six‑month late notice of appeal dismissed due to gross non‑compliance and inadequate explanation.
Civil procedure — condonation for late notice of appeal — gross non‑compliance with court rules; defective condonation filed in magistrates’ court (Magistrates’ Courts rule 60(5)(a)); rescission of default judgment — requirement to disclose grounds of defence (Magistrates’ Courts rule 49(3)); prospects of success weighed against delay and prejudice; respondent’s short delay in filing answering affidavit condoned.
14 January 2026
Summary judgment refused where defendants disclosed bona fide triable defences and a substantial counterclaim.
Civil procedure – Summary judgment – Requirement that defendant fully disclose nature, grounds and material facts of a bona fide defence – Illiquidity and absence of annexed price schedule/delivery notes – Certificate of balance and founding affidavit by legal practitioner – Counterclaim for unjustified enrichment.
8 January 2026
December 2025
Condonation and leave to appeal refused for inordinate delay, lack of prospects, and absent locus standi.
Civil procedure — condonation for late filing — Melane/Grootboom factors; Leave to appeal — s 17 Superior Courts Act — reasonable prospects of success; Locus standi — effect of final liquidation on director's capacity; Costs — personal costs order (party-and-party).
29 December 2025
Assault and contravention of a protection order are distinct offences; convictions confirmed, count 3 remitted for sentencing.
Criminal law — duplication of convictions — assault and contravention of protection order arising from same incident — distinct offences with different elements; sentencing, not conviction, addresses double punishment risk.
19 December 2025
A duplicate theft conviction was set aside and the matter remitted for sentencing on the substantive housebreaking count.
Criminal law — Duplication of convictions — Splitting a single substantive offence into multiple counts — Special review under s 116(3) — Setting aside duplicated conviction and remitting for sentencing.
19 December 2025
Condonation for 21-day late statutory notice refused because prospects of success were lacking and state would be prejudiced.
Institution of Legal Proceedings against Certain Organs of State Act s 3(4) – condonation for late notice – conjunctive requirements: no prescription, good cause, no unreasonable prejudice – prospects of success relevant to good cause – malicious arrest, detention and prosecution claims – service on correct organ of state.
18 December 2025
Appeal dismissed: conviction and life sentence upheld after proper evaluation of evidence and sentencing discretion.
Criminal law – Sexual offences – Evaluation of complainant’s credibility and need for caution – Corroboration by sibling and accused’s statement – Sentencing – Substantial and compelling circumstances under S v Malgas – Life imprisonment for rape of a minor by a parent.
18 December 2025
Hospital records and related documentation constituted substantial compliance with s 24, so the Fund's special pleas were dismissed.
Road Accident Fund Act s 24 – procedure for lodging claims – substantial compliance – medical report requirements (s 24(2)(a)) – hospital records as substantial compliance – s 24(5) objection within 60 days – special pleas of non‑compliance, prematurity and prescription dismissed.
17 December 2025
A notice of bar is irregular where the respondent’s attorney’s authority is disputed under rule 7(1) until court determination.
Procedure — Uniform Rules of Court — Rule 7(1): dispute of attorney’s authority — court must be satisfied of authority; filing power of attorney not automatically dispositive. Rule 30: irregular steps — notice of bar set aside. Rule 22(1): 20-day pleading period postponed until court determination of authority.
12 December 2025
Notice of bar served while attorney authority was disputed is irregular; court must be satisfied of authority before further steps.
Civil procedure — Uniform Rules of Court — Rule 7(1) — disputed authority of attorney — court must be satisfied of authority before attorney may act; production of power of attorney or interlocutory proceeding may be required. Civil procedure — Rule 30 — irregular steps — setting aside notice of bar served while authority disputed. Civil procedure — Rule 22(1) — time for plea/exception runs from day after court determines authority.
12 December 2025
Contempt application failed because the municipality’s non‑compliance was not proved willful or mala fide beyond reasonable doubt.
Civil contempt — consent order — requirements: existence, service, non‑compliance, willfulness and mala fides beyond reasonable doubt — Plascon‑Evans evidential approach — settlement as court order does not per se bar other remedies — practical impediments to performance (encumbrances, bond terms, costs) may raise reasonable doubt.
11 December 2025
Contempt not proved beyond reasonable doubt; maintenance and related disputes referred to the Maintenance Court, each party to bear own costs.
Maintenance orders – contempt of court – requirements of existence, service, disobedience, wilfulness and mala fides – Plascon‑Evans rule – financial incapacity and change of circumstances – referral to Maintenance Court under Maintenance Act – best interests of children and inappropriate use of High Court to resolve parental acrimony.
9 December 2025
Genuine factual disputes on existence and terms of an alleged partnership required referral to oral evidence; late reply condoned.
Civil procedure – motion proceedings vs action – material disputes of fact – Rule 6(5)(g) referral to oral evidence; Partnership law – requirements for (universal/ordinary) partnership between spouses married out of community; Admissibility of new evidence in reply – introduction of bank statement (annexure "ISA 08") and discretionary grant of leave to file further affidavit.
5 December 2025
Whether RAF breached judgment by failing to pay interest and taxed costs and whether contempt orders should be enforced.
Road Accident Fund — failure to pay interest and taxed costs under judgment — typographical/identity‑number error in pleadings — bona fide clerical mistake — contempt proceedings against CEO and execution of suspended sentence — rescission application to set aside prior orders — costs.
5 December 2025
Failure to appear on bail is a statutory offence under s67A requiring a formal charge and trial; summary inquiry impermissible.
Criminal Procedure Act s67A – failure to appear on bail – statutory offence – requirement for formal charge-sheet and full trial – summary inquiry impermissible – State to prove guilt beyond reasonable doubt.
5 December 2025
Court applied a 10% post‑morbid contingency and awarded the plaintiff R283,756 for future loss of earnings.
Road Accident Fund – quantum – future loss of earnings – contingency deductions – admissibility of uncontested expert and actuarial evidence – court’s discretionary assessment based on claimant’s personal circumstances.
5 December 2025
The applicant was partly negligent; the respondent liable for 75% of proven damages.
Road traffic negligence – two-lane straight road – potholes causing oncoming heavy vehicle to veer across centre line – weight of witness estimates and photographs – duty of driver on correct side to take reasonable evasive action – sudden emergency principle considered – apportionment of damages 75/25 in favour of plaintiff.
3 December 2025
Court dismissed review of Master's withdrawal of s18(3) letters, directing Chief Master to review under s95.
Administration of Estates Act – section 18(3) small estates procedure – issuance and withdrawal of letters of authority; section 95 Chief Master's review as primary remedy; inapplicability of section 54 to section 18(3) representatives; duty to disclose assets and descendants; potential need for executor dative.
3 December 2025