Court of Appeal of Zambia

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1,991 judgments
Citation
Judgment date
March 2026
Appeal dismissed: occupation period, unjust enrichment, period-specific exchange rates and costs award were correctly applied by the assessor.
Assessment of damages – determination of occupation period and surrender by delivery of keys – unjust enrichment as bar to retaining benefit without restitution – conversion of foreign currency using period-specific Bank of Zambia rates – duty to mitigate – costs following the event.
6 March 2026
Acting and responsibility allowances require formal appointment; whistleblower protection and constructive dismissal not established.
Employment law — acting and responsibility allowances — entitlement requires formal appointment; Whistleblower protection — good faith and procedural compliance required; Constructive dismissal — employee must prove employer’s conduct amounted to fundamental breach.
5 March 2026
February 2026
Acceptance of instalment payments varied the loan; duress not established; counterclaim for additional loan unproven.
Contract variation — instalment acceptance as mutual variation and consideration; Duress — threats to report or reminders not automatically vitiating consent; Burden of proof — counterclaim must be proved on balance of probabilities; Cheques and payment patterns as evidence of acknowledgement of debt and ongoing indebtedness.
27 February 2026
Filing a defence under the amended High Court Rules does not waive the right to challenge originating process irregularities.
Civil procedure – High Court Rules amended by S.I No. 58 of 2020 – Order 11/1 – filing of defence does not waive right to challenge irregularity of writ; Practice Direction No. 4 of 1977 – period for entry of appearance – service of process on advocates; duty of trial courts to adjudicate all issues
27 February 2026
Whether a documented sale with option to repurchase was a disguised loan and if alleged upfront deductions were proved.
Property law – substance over form: sale with option to repurchase vs disguised loan; evidentiary requirement to authenticate handwritten documents; mesne profits/occupational fees for unauthorized occupation; discretionary award of costs to successful party.
25 February 2026
Appellant’s non-payment justified rescission and rental compensation; board‑resolution and Rent Act defences rejected.
Company law – authority to commence proceedings – board resolution only required if company’s articles so provide; Contract law – rescission for breach by non‑payment; Unjust enrichment – occupation without payment; Rent Act inapplicable to sale/rescission disputes; Civil procedure – case management and refusal to re-open/ amend pleadings.
24 February 2026
Use of Originating Summons for a breach of contract claim was wrongful and deprived the court of jurisdiction.
Civil procedure — mode of commencement — Order VI Rule 1 HCR — writ of summons primary; Originating Summons confined to matters disposable in chambers; Order 30 Rule 11 discretion limited; breach of contract/default on loan not amenable to summary chamber proceedings; wrong commencement deprives court of jurisdiction; proceedings a nullity.
18 February 2026
Leave to seek judicial review of a JCC recommendation was granted; High Court is proper forum despite potential constitutional issues.
Judicial review – Order 53 RSC – leave to apply – locus standi; Judicial Complaints Commission – jurisdiction to hear complaints after retirement; Procedural impropriety – calling witnesses for complainants and natural justice; Constitutional questions – referral to Constitutional Court vs. High Court jurisdiction; Mootness where executive acts on administrative recommendation
18 February 2026
Whether JCC recommendations reopening complaints are amenable to judicial review and whether leave to seek such review should be granted.
Judicial review — Order 53 RSC — leave as filter for arguable case; Judicial Complaints Commission — jurisdiction, procedural impropriety, natural justice; prerogative remedies in High Court; constitutional issues referable to Constitutional Court; recommendations vs decisions.
17 February 2026
Non-conviction forfeiture upheld where licence showed objective signs of forgery; respondent may not recover profit costs.
Forfeiture — Non-conviction-based forfeiture permissible under s.31(4) FPOCA; forgery qualifies as a "serious offence"; admissibility of bank statements—Evidence (Banker's Book) Act compliance required; seizure notices—authenticity and proper record; costs—State may recover costs but in-house counsel not entitled to profit costs.
6 February 2026
Renewed application for interim injunction refused: damages adequate and balance of convenience favours respondents with registered title.
Civil procedure – interim injunction – application of American Cynamid principles; competing claims to land – customary rights versus registered Certificate of Title; adequacy of damages; balance of convenience; maintenance of status quo.
5 February 2026
Whether a purported sale used as security for a debt is a question of fact requiring full trial, not summary disposal.
Contract law — consideration (forbearance to sue third party); Registration of land instruments — Lands and Deeds Registry Act ss.4,6 — extension/curability; Housing Act/formalities and repeal; Transactions in land as security versus sale — intention of parties; Summary procedure — Order 14A RSC — issues requiring trial; Caveat removal procedure.
5 February 2026
January 2026
Summary dismissal upheld where employee failed to prove authorization and disciplinary process complied with collective agreement.
Employment law — Summary dismissal for dishonesty — Internal disciplinary proceedings may proceed despite concurrent criminal proceedings — Burden of proof on employee to show authorization — Procedural delay not necessarily fatal — Issues not raised at trial cannot be raised on appeal.
29 January 2026
A court cannot make fresh orders after delivering judgment; such post-judgment orders are void as functus officio.
Civil procedure — Functus officio — Whether a court may vary or add to its judgment after delivery — Industrial Relations Division lacks power to review/alter judgment once final — Orders made post-judgment in committal proceedings void for want of jurisdiction; consequent dismissal of related cross-appeal.
29 January 2026
Allowance components of "salary" must be included in redundancy calculations where "salary" is pleaded or contracted generally.
Labour law — redundancy pay — meaning of "salary" — inclusion of allowances in terminal benefits; accrued conditions of service; retrospective application of Employment Code; pleadings and scope of assessment.
28 January 2026
A constitutional petition cannot reopen issues already finally decided by the Supreme Court; the appellant lacked locus standi.
Constitutional petitions – Article 28(1)(a) – Procedure – Order 3 Rule 2 (High Court Rules) not a basis for final dismissal of constitutional petitions – inherent jurisdiction to determine locus standi, res judicata and abuse of process – forfeiture under Corrupt Practices (Disposal of Recovered Property) Regulations – effect of a prior Supreme Court determination.
28 January 2026
A preliminary Rule 14A determination was inappropriate where the Circular's applicability required full trial evidence.
Administrative law – Cabinet Office Circular No. 3 of 2001 – Secondment – Order 14A (RSC) – Preliminary questions – Suitability for summary determination – Statutory body/corporate personality – Need for full trial.
27 January 2026
Appellant held vicariously liable where its employee had apparent authority to contract with the respondent.
Agency and vicarious liability – employee acting within scope of employment – apparent/ostensible authority binds principal – Royal British Bank v. Turquand (indoor management) – fraudulent or unauthorized acts within apparent authority still bind principal – costs follow the event
27 January 2026
Strike‑out is draconian; pleadings here disclosed a reasonable negligence cause and the case was remitted for trial.
Civil procedure — Pleadings — Particulars for negligence — Misrepresentation as relief — Strike‑out power sparingly exercised — Order 18 particulars; Order 11 Rule 1 compliance.
27 January 2026
Extension of time to appeal to the Court of Appeal lies exclusively to that court; High Court orders in that regard are void.
Civil procedure – extension of time to appeal – Order 13 Rule 3 CARs – High Court lacks jurisdiction to extend time to appeal to the Court of Appeal – orders void ab initio – renewal before Court of Appeal incompetent.
26 January 2026
Court refused to allow a belated affidavit in opposition, finding the applicant had slept on its procedural right.
Civil procedure – interlocutory applications – inherent jurisdiction (Order 29/1A/10 RSC) – affidavit in opposition – procedural default – Order 57/4/2 RSC – failure to file affidavit before hearing – no revival of right post‑hearing – costs.
22 January 2026
Whether a claim for backdated maintenance was res judicata and whether earlier judicial remarks were obiter dictum.
Family law – maintenance and school fees – res judicata; rehearing and scope of pleadings; obiter dictum v. substantive ruling; abuse of process; costs follow event.
13 January 2026
December 2025
Court upheld dismissal: tribunal had jurisdiction and sufficient factual basis; procedural lapses were not prejudicial.
Employment law – disciplinary proceedings – judicial review limited to jurisdiction, adherence to procedure and existence of substratum of facts – accumulation of misconduct – procedural irregularities not necessarily vitiating dismissal – bias/perceived interest on panel assessed for prejudice.
31 December 2025
Time to file a notice of appeal runs from judgment delivery/sealing, not from service; extension under Order 13 CAR required if late.
Civil procedure — Appeal time limits — Order 10 Rule 3(5) CAR — thirty-day period runs from date of judgment (delivery/sealing), not from service — out-of-time appeals require extension under Order 13 CAR.
31 December 2025
Whether a judge must recuse when a confidential JCC complaint exists and the applicant refuses to disclose its substance.
Judicial recusal — complaint to Judicial Complaints Commission — confidentiality vs requirement to disclose particulars — reasonable apprehension of bias — administrative recusal after consultation with Judge President.
31 December 2025
Specific performance for land requires a written contract; Certificates of Title are conclusive absent pleaded fraud.
Property law – Specific performance – Statute of Frauds requirement for written contract or memorandum for sale of land; Certificate of Title conclusive absent pleaded fraud; fresh evidence on appeal inadmissible without leave.
24 December 2025
Specific performance of land sale requires a written contract; title deeds are conclusive unless fraud is pleaded and proved.
Property law – Specific performance; Statute of Frauds (requirement of writing for land sales); Lands and Deeds Registry Act – Certificate of Title conclusive absent pleaded and proved fraud; inadmissibility of fresh evidence on appeal; remedy not available against non-contracting parties.
24 December 2025
Appellate court corrected a mathematical error, found an equitable mortgage, ordered title returned and K1,000 outstanding plus interest.
Loan secured by property; equitable mortgage vs forward purchase; appellate correction of clerical/mathematical error; entitlement to return of title deeds; interest on outstanding balance.
24 December 2025
A lengthy ground challenging insufficiency of evidence was held to substantially comply with Court of Appeal Rule requirements.
Civil procedure — Court of Appeal Rules Order X Rule 9(2) — memorandum of appeal must concisely state grounds without narrative — practical test: discernible complaint and absence of prejudice — grounds challenging insufficiency of evidence and proof of ownership.
22 December 2025
Applicant failed to show sufficient, evidenced cause (bereavement unsupported) to justify extension of time to appeal; application dismissed.
Civil procedure – extension of time – Order XIII Rule 3(1) – sufficient cause required; Bereavement as excuse – need for corroborative evidence (medical records/death certificate); Finality of litigation – prejudice from reopening enforcement of long-standing judgment; Constitutional principle (Article 118(2)(e)) – justice without undue regard to technicalities does not permit flouting procedural rules.
11 December 2025
Court granted stay of execution pending appeal to preserve status quo and prevent irreparable harm to pension provider.
Stay of execution – Court of Appeal Rules Order 10 r 5 – appeal not stay automatically – discretionary relief – preview of prospects of success – balance of convenience – irreparable harm – preservation of status quo – monetary judgment against pension provider.
11 December 2025
Stay of execution refused where appellant failed to show strong prospects of success or special circumstances in a land-title dispute.
Civil procedure – Stay of execution pending appeal; Appeal standards on factual findings; Land allocation – Circular No.1 of 1985 compliance; Certificate of title – conclusive absent fraud; Prospects of success and irreparable harm test.
9 December 2025
Leave to appeal refused: mesne profits award unsupported where tenant not a trespasser; no public importance or prospects.
Civil procedure – leave to appeal to the Supreme Court (Court of Appeal Act s.13(3)) – mesne profits – landlord-tenant obligations – requirement of wrongful deprivation of possession – public importance threshold for leave to appeal.
5 December 2025
Use of the Rules of the Supreme Court in the Industrial Relations Court was incompetent; appeal dismissed and matter remitted for merits.
Industrial Relations Court — applicability of Rules of the Supreme Court — conditional offer of employment — rescission for failed pre-employment checks — competence of preliminary point of law under Order 14A RSC — remit to determine merits.
5 December 2025
Court refused to dismiss appeal for want of service where appellant had a pending application for leave to extend time.
Court of Appeal Rules — Order 10 Rule 3(9): mandatory service of notice and memorandum of appeal; Order 13 Rule 3(3): discretion to extend time after prescribed period; dismissal for want of service; jurisdiction to grant leave to apply for extension; distinction where service was effected out of time without leave; dismissal as sparing remedy; requirement of mala fides/inordinate delay for dismissal.
5 December 2025
Court may grant unpleaded unfair dismissal remedy; respondent wrongfully dismissed; damages reduced to eight months.
Industrial Relations Court – section 85(5) – substantial justice may permit granting of unpleaded remedies; wrongful dismissal – breach of disciplinary procedure and natural justice; sick leave – accrual of annual leave and entitlement to payment; costs under Rule 44 – awarded only for unreasonable, vexatious or improper conduct; measure of damages – ordinarily notice period, excessive awards reduced.
5 December 2025
High Court leave to appeal can constitute exceptional circumstances justifying bail pending appeal and postponement of fine.
Criminal law – Bail pending appeal – Exceptional circumstances – Prospects of success and likelihood of serving substantial portion of sentence – Leave to appeal as indicator – Postponement of fine pending appeal.
5 December 2025
Proceedings on the merits were adjourned because a pending appeal on the Court's jurisdiction must be finally determined first.
Jurisdiction challenge – Effect of pending leave to appeal – Suspension of further substantive proceedings; Interlocutory rulings – binding until stayed but subject to apex court review; Contempt proceedings – distinct and may proceed; Judicial economy – cannot justify orders if jurisdiction doubtful.
4 December 2025
Failure to comply with mandatory Order X time limits and to obtain leave to serve or file out of time renders an appeal incompetent.
Appeal procedure – Order X Court of Appeal Rules – mandatory time limits for service of notice/memorandum and record/heads – failure to obtain leave to serve/file out of time renders appeal incompetent.
4 December 2025
Re‑charging an employee on the same facts after successful appeal is an abuse of process; dismissal was unfair and damages awarded.
Employment law — disciplinary procedure — re‑charging employee on same facts after successful appeal — abuse of process and breach of natural justice; constructive dismissal — resignation with future effective date; unfair dismissal — enhanced damages (24 months' salary) awarded.
4 December 2025
Actual commercial use and parties' conduct can override certificate-based classification excluding statutory protection.
Landlord and Tenant (Business Premises) Act – classification of premises – effect of actual use and parties' conduct versus certificate of title – prima facie nature of title – requirement for accurate land identification – judicial estoppel against inconsistent positions.
4 December 2025
The Court of Appeal refused to set aside its full-bench ruling, holding it lacks power to re-open such decisions absent exceptional circumstances.
Inherent jurisdiction; functus officio; re-opening full-bench rulings; slip/correction rule limited to clerical mistakes; finality of litigation; stay of execution.
4 December 2025
Affidavits in reply must not introduce new issues; offending paragraphs were expunged to prevent prejudice to the respondent.
Civil procedure – Affidavits in interlocutory proceedings – Affidavit in reply must be confined to matters raised in opposition – Order 41 RSC and Court of Appeal Rules – Expungement of scandalous, irrelevant or oppressive material – Inherent jurisdiction to strike out – Joinder application context.
3 December 2025
Dismissal for absenteeism was procedurally unfair; reinstatement with arrears and continuity of service was ordered.
Employment law — unfair dismissal — trade union protection (s.5(1)(g) I&L Act) requires causal link to union activity — secondment and disciplinary jurisdiction — procedural fairness (right to have appeal considered) — reinstatement discretionary but warranted in exceptional public‑sector circumstances — continuity of service and arrears with interest.
3 December 2025
Applications arising from a full court judgment must be brought to the full court; single judges may adjourn under Order X r.6.
Civil procedure — jurisdiction of single judge v full court — applications arising from full court judgments — Order X r.6 — adjournment to full court.
3 December 2025
Failure to file copies of the proceedings and affidavits before the single-judge decision made the renewed motion incompetent and dismissed with costs.
Civil procedure — Court of Appeal — Order X r.2(8) — renewed application from single-judge decision — mandatory requirement to file copies of proceedings and affidavits placed before single judge — no fresh material permitted — improper framing as appeal renders motion incompetent.
2 December 2025
A stay pending appeal was granted because the appellant showed arguable prospects of success and irreparable harm to land interests.
Civil procedure — Stay of execution pending appeal — Necessity to demonstrate prospects of success and irreparable harm — Land disputes and risk of appeal becoming nugatory — Court’s discretion to preview prospects of success.
1 December 2025
Court upheld leave to file the respondent's employment complaint out of time and validated the Power of Attorney.
Employment law – limitation of actions under s.85(3) Industrial and Labour Relations Act – court’s discretion to extend time; jurisdiction once leave granted; res judicata requires a final judgment on the merits; Authentication of Documents Act – applies only to instruments executed outside Zambia; admissibility of Power of Attorney executed in Zambia.
1 December 2025
Court granted stay pending appeal, finding arguable appeal grounds and no real prejudice despite insufficient proof of irreparable harm.
Civil procedure — Stay of execution — Order 10 Rule 5 — Test: reasonable prospects of success and irreparable harm — Solvency of judgment creditor relevant — Preservation of status quo — Service irregularity immaterial absent prejudice.
1 December 2025
A single judge lacks jurisdiction to strike out an entire appeal; such a summons is incompetent and dismissed.
Court of Appeal — single judge jurisdiction — Order VII Rule 2(1) and Section 9 — competence to determine interlocutory applications — strike out appeal — abuse of process — company board authority — decisions without jurisdiction void ab initio.
1 December 2025