Court of Appeal of Zambia - 1969

10 judgments
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Results. 10 judgments found.

10 judgments
December 1969
Recent possession allows an inference of theft but does not shift the burden of proof; misdirections were not fatal.
  • Criminal law — Theft — Recent possession doctrine limited to permissible inferences of fact; does not shift prosecution’s burden of proof; misdirection by trial judge; proviso applied.
17 December 1969
May 1969
Whether participants in a concerted assault are principals under s.21 when an unforeseen fatal result occurs.
  • Criminal law — Principal offenders — Joint assault — Application of Penal Code s.21(a) and s.21(c) to deaths supervening from concerted assaults — Where multiple assailants act in concert each may be a principal; abettors liable where agreed acts/ints produce unforeseen fatal result.
13 May 1969
Section 29 protects bona fide tortious acts but does not shield Administrator‑General from costs arising from legal acts.
  • Administration of estates — Administrator‑General’s liability — Section 29 Administrator‑General Ordinance protects bona fide tortious acts but not legal consequences of legal acts — Liability de bonis propriis for costs of unsuccessful representative litigation.
13 May 1969
March 1969
The prosecution cannot rely on an accused’s words when called to plead to prove the elements of the offence.
  • Criminal procedure — Pleading by accused — Statements made when called upon to plead are not part of the prosecution’s case — Prosecution must prove all ingredients of the offence by independent evidence (see R v Muchuma).
18 March 1969
Whether automatism was properly raised and whether the appellants' assault legally caused death under section 184(e).
  • Criminal law — Automatism under s.10 Penal Code — burden on prosecution to negative automatism beyond reasonable doubt; where automatism derives from disease affecting the mind, insanity rules (s.13) apply and accused must prove on balance of probabilities. Defence must lay proper foundation (normally medical evidence)
  • Causation — s.184(e) requires close temporal/transactional "accompaniment"; independent intervening acts may break chain of legal causation
18 March 1969
The Court of Appeal lacks statutory power under s14(3) to suspend or activate a sentence; only trial court or s300 High Court can.
  • Court of Appeal jurisdiction; suspension of sentence; interpretation of s14(3) Court of Appeal for Zambia Ordinance; s14A and s300 Criminal Procedure Code; appellate powers to make incidental or consequential orders.
18 March 1969
February 1969
Absence of stated reasons does not ordinarily invalidate a sentence; legal aid for appeals against sentence is rarely justified.
  • Criminal procedure — Sentencing — No general duty to state reasons for sentence; absence of reasons does not imply improper consideration — Magistrate’s jurisdiction to sentence — Grant of legal aid for appeal against sentence rarely justifiable.
18 February 1969
An instrument signed by the respondent acknowledging a loan and creating the sole security is chargeable under Head 8(1).
  • Stamp duty — Debenture — Whether instrument is a security or mere receipt — Signature by one party sufficient to create enforceable agreement — Interpretation and General Provisions Ordinance s.4(4) bars ejusdem generis unless qualifying word used — Head 8(1) applies to debenture that is the only or principal security.
18 February 1969
January 1969
A member does not vacate their seat if an appealed >6-month sentence is quashed and reduced to six months or less.
  • Constitutional law — National Assembly — automatic vacation of seat under s.65(2); no overt act required — Criminal appeal practice does not suspend vacancy; where an appealed sentence is quashed and substituted, the quashing removes the disqualifying sentence for s.65(2)(c).
14 January 1969
An assessed loss under s.13(3)(iv) does not include part‑year trading losses before a mid‑year change of ownership; Commissioner cannot split the year's assessed loss.
  • Income tax — s.13(3)(iv) — change of ownership — whether "assessed loss" includes part‑year trading losses — assessed loss not ascertainable mid‑year; proviso (v) may treat current‑year loss on winding up as assessed loss; legislative intent to prevent acquisition of tax advantage by takeover.
14 January 1969