Court of Appeal of Zambia - 2017

96 judgments
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Results. 96 judgments found.

96 judgments
December 2017
A consent order consolidating actions and withdrawing pending interlocutory applications barred later pursuit of the abandoned claims by res judicata.
  • Civil procedure — consolidation of actions — consent order withdrawing "all pending interlocutory applications" — effect of consolidation on substantive claims — consent withdrawal as abandonment — res judicata (Henderson v Henderson) — stare decisis and binding construction by higher court.
18 December 2017
Order 113 summary proceedings cannot resolve real boundary or title disputes; a full trial is required.
  • Procedure — Order 113 RSC (summary possession) limited to non-contentious squatters' cases; boundary and title disputes require trial in open court; cancellation of certificate of title inappropriate in chambers; fresh evidence must be tested at trial.
15 December 2017
Appellant failed to prove slander; trial court’s credibility finding upheld and appeal dismissed.
  • Defamation — Slander: elements (defamatory meaning, reference to plaintiff, publication to third party, proof of reputational injury); credibility and demeanour as basis for findings of fact; appellate restraint on overturning factual findings.
8 December 2017
Periodic monthly tenancy (not 29‑month fixed term); abandonment without notice constituted surrender, unilateral rent increase invalid.
  • Landlord and Tenant — periodic (monthly) tenancy — 29 months relates to repayment of third‑party investment, not term — termination requires notice to quit or inferred surrender — unilateral rent increase invalid — tenant liable for six months' rent for abandonment; service charges, interest and costs awarded.
5 December 2017
A short delay and inability to obtain the transcript justified extension to file the record of appeal.
  • Civil procedure — extension of time to take steps in an appeal — Order XIII r3 — length of delay and sufficiency of reasons — unavailability of transcript as ground — merits not considered where application only seeks to file record of appeal.
4 December 2017
November 2017
Whether uniformed military personnel’s trespass and intimidation were within scope of employment, attracting vicarious liability.
  • Vicarious liability — scope of employment — close connection test (Lister) — trespass and intimidation by uniformed military personnel — appellate interference with factual findings.
29 November 2017
29 November 2017
Stay of taxation pending JCC investigation refused for lack of exceptional circumstances or demonstrated prejudice.
  • Civil procedure — taxation — application to stay taxation pending Judicial Complaints Commission investigation — discretionary remedy requiring exceptional circumstances, demonstrable merit and irreparable harm; complaint against judge does not automatically warrant stay.
28 November 2017
An application to file a Notice of Appeal out of time must be made first to the court below before renewal in the Court of Appeal.
  • Civil procedure — extension of time — application to file Notice of Appeal out of time — jurisdictional requirement to apply first in the court below before renewing in the Court of Appeal.
28 November 2017
Court granted a final seven‑day extension to file the record of appeal, finding delay not inordinate and no prejudice to respondents.
  • Civil procedure — Appeal — Extension of time to file record of appeal — Order 13 Rule 3(3) Court of Appeal Rules — Inordinate delay — Prejudice to respondent — Exercise of judicial discretion.
28 November 2017
Court allowed final extension to file record of appeal, finding delay not inordinate nor prejudicial.
  • Civil procedure — appeal — extension of time to file record of appeal — Order 13 Rule 3(3) Court of Appeal Rules — inordinate delay a question of fact — prejudice to respondent — dismissal for want of prosecution.
28 November 2017
Inordinate delay and alleged counsel incompetence do not justify extension of time to appeal or a stay of execution.
  • Civil procedure — extension of time to appeal — discretionary relief: factors include reasons for delay, length of delay, applicant’s conduct and merits; counsel’s negligence not a sufficient ground; stay of execution.
28 November 2017
Delay of over a year and reliance on former counsel’s alleged incompetence failed to justify extension of time to appeal; stay discharged.
  • Civil procedure — extension of time to appeal — discretion requires good cause — length and reasons for delay — incompetence of former counsel not a ground — stay of execution discharged — finality of litigation.
28 November 2017
Court granted leave to seek extension to file record of appeal out of time but warned against procedural laxity.
  • Civil procedure — extension and enlargement of time — Order 13/3 CAR — leave to apply under subrule (3) where 60 and 21 day periods have elapsed — procedural laxity — discretion to grant relief.
10 November 2017
Specific performance ordered where vendor breached by refusing agreed road reserve; purchaser justified in withholding balance and title.
  • Contract for sale of land — incorporation of sketch plan — agreed 20m road reserve — vendor’s survey omitted reserve — fundamental breach — purchaser’s lien over title deed — specific performance appropriate — rescission ineffective — time not of the essence.
9 November 2017
Where "pay" is undefined, it is interpreted to include salary plus allowances; long service gratuity and retirement benefits are distinct entitlements.
  • Employment law — contractual interpretation — meaning of "pay" and "salary"; long service gratuity vs retirement benefits; calculation of terminal benefits; housing allowance continuation; unjust enrichment.
9 November 2017
Execution of a deputy registrar’s order does not bar a judge from rehearing the appeal and exercising fresh discretion.
  • Civil procedure — Appeal from deputy registrar to judge — Rehearing and unfettered judicial discretion; execution of registrar’s order does not oust jurisdiction — Order XXX r 10 High Court Rules — No automatic stay of proceedings.
6 November 2017
A judge may rehear appeals from a deputy registrar despite execution of the registrar's order; execution does not oust jurisdiction.
  • Civil procedure — Appeal from deputy registrar to judge — Rehearing with unfettered discretion — Execution of registrar's order pending appeal does not oust jurisdiction — Order XXX r 10 High Court Rules.
6 November 2017
October 2017
Application to admit fresh evidence on appeal dismissed: evidence discoverable with diligence and would not have materially altered grant of specific performance.
  • Civil procedure — fresh/further evidence on appeal — test: reasonable diligence, credibility, probable material effect (Ladd v Marshall principle) — public/accessible documents — land law — capacity to contract v capacity to own land — specific performance and enforceability dependent on conveyancing formalities and state/presidential consent.
31 October 2017
No mesne profits absent landlord–tenant relationship; purchaser awarded damages for delayed possession and unjust enrichment remedy for guest wing occupancy.
  • Contract and remedies — specific performance and damages for delayed possession; mesne profits require landlord–tenant relationship; Statute of Frauds and written memorandum for land transactions; unjust enrichment for occupancy benefit; vendor liable for property transfer tax.
31 October 2017
Habeas corpus is inapplicable once detention ceases; appeal dismissed as academic and each party bears own costs.
  • Habeas corpus — prerogative remedy to secure immediate release — inapplicable where detention has ceased; mootness of habeas claims after nolle prosequi; limits on using habeas corpus to pre-empt criminal proceedings.
30 October 2017
Interlocutory injunction refused where applicants were squatters, no serious question to be tried; appeal dismissed.
  • Civil procedure — interlocutory injunctions; requirements: serious question to be tried, adequacy of damages, balance of convenience, clean hands — adverse possession/squatters; appellate limitation on facts not raised below.
26 October 2017
Court refused judgment on admission where illegible handwritten endorsement and lack of certified typewritten copy failed Rule requirements.
  • Civil procedure — Judgment on admission — Admissibility of handwritten endorsements — Requirement under Order V Rule 19 for certified typewritten/printed copy — Court satisfaction as to genuineness of defendant's signature under Order XXI Rule 5 — Triable issues where defence alleges failure of consideration.
26 October 2017
Whether directors may be joined and held personally liable under Section 383 for company debts where fraudulent trading is alleged.
  • Companies law — corporate personality — Salomon principle — piercing the corporate veil — Section 383 Companies Act — fraudulent trading — personal liability of directors — joinder in originating proceedings — creditor's remedy — multiplicity of actions
13 October 2017
A referred and exhibited agency agreement and an averment by necessary implication negated deemed admissions; judgment on admission was therefore improper.
  • Civil procedure — judgment on admission — Order 53 r.6 and Order 18/13 — pleadings — incorporation of exhibited contract into defence — traverse by necessary implication — agency — scope of papers-only applications.
13 October 2017
Ill-health and prior trial bail did not amount to exceptional circumstances to grant bail pending appeal.
  • Bail pending appeal — Court of Appeal Act s.18(1) — requirements: prima facie prospects of success, exceptional circumstances, or risk of serving substantial sentence — medical grounds evaluated — prior trial bail not determinative.
12 October 2017
Buyer entitled to reject unmerchantable goods; exclusion clause could not negate statutory implied terms and damages limited by duty to mitigate.
  • Sale of Goods Act — implied condition as to merchantability and fitness for purpose — buyer entitled to reject unmerchantable goods; Exclusion clauses — narrow construction; inability to exclude statutory implied conditions unless expressly done; Consumer protection/unfair terms; Duty to mitigate — claimant must take reasonable steps to minimise loss; Appellate review — factual findings not to be disturbed unless perverse or unsupported by evidence.
11 October 2017
The appellant failed to show a clear right or irreparable harm, so an interim injunction was inappropriate.
  • Interlocutory injunctions — requirement of clear right and irreparable harm — damages as adequate remedy — burden of proof in civil cases — evidential weight of documentary exhibits.
5 October 2017
Summary dismissals were wrongful and unfair for lack of charges and a hearing; damages beyond notice upheld, leave pay to be assessed.
  • Employment law — wrongful and unfair dismissal — disciplinary procedure and audi — misapplication of disciplinary code clauses — damages beyond contractual notice for abrupt summary dismissal — entitlement to pay for days worked and accrued leave.
5 October 2017
Employee's participation in restructuring consultations and failure to object amounted to acquiescence; retrenchment and payment were lawful.
  • Employment law — redundancy and retrenchment — variation of written contract by acquiescence — notice, consultation and opportunity to object — computation of redundancy benefits (use of s.26B formula).
5 October 2017
Amended s85(3) allows judicial discretion to admit late complaints where union and Labour Office engagement justifies delay.
  • Industrial & Labour Relations Act s85(3) — interpretation post-2008 amendment; discretion to extend time; exhaustion of administrative channels; union and Labour Office engagement as sufficient reasons for delay; leave to file complaint out of time.
2 October 2017
September 2017
Appeal dismissed: dismissal upheld where disciplinary procedure was followed, evidence supported misconduct, and appellant voluntarily absented himself.
  • Employment law — Disciplinary procedure and dismissal — Sufficiency of evidence to support misconduct; Natural justice — audi alteram partem and hearings in absence; Appeal competence under Section 97 ILRA — points of law or mixed law and fact; Supervisory responsibility for departmental security; Distinction between wrongful and unfair dismissal.
28 September 2017
Registered title is conclusive absent specifically pleaded and proved fraud; a stranger to a settlement cannot acquire title by that settlement.
  • Certificate of title — conclusiveness under Lands and Deeds Registry Act — privity of contract — receipt ambiguous as to purpose — requirement to plead and strictly prove fraud — findings of fact disturbed where at variance with evidence.
28 September 2017
Defective voire dire led to exclusion of child evidence, but the deceased’s wife’s credible testimony and corroboration sustained the murder conviction.
  • Criminal law — Voir dire of child witnesses; admissibility and caution with juvenile evidence; suspect witnesses and requirement for corroboration; identification evidence and absence of fingerprint evidence; common design and malice aforethought in murder.
27 September 2017
Court may proceed in defendant's absence, but plaintiff must prove document authenticity; attorney-in-fact cannot attest to principal's unknown facts.
  • Civil procedure — trial in defendant's absence (Order 35 r.3); Evidence — admissibility and proof of documents; Power of attorney — limits on attorney-in-fact giving evidence about principal's personal knowledge; Fraud/forgery — requirement for particular pleadings and proof; Burden of proof — plaintiff must prove debt on balance of probabilities.
26 September 2017
The Statement of Claim failed to disclose a cause of action and the appellant lacked locus standi; appeal dismissed.
  • Pleadings — Cause of action — Requirement to plead facts giving rise to liability; Locus standi — intertwined with reasonable cause of action; Pleadings procedure — further and better particulars and striking out; Court’s power to dismiss on its own motion (Order 3/2 HCR).
22 September 2017
Court partly allows appeal, reduces respondent’s damages and orders recalculation accounting for tax and Workers Compensation deductions.
  • Personal injury — assessment of damages — heads: pain and suffering, loss of amenities, permanent disability, loss of future/prospective earnings; unpleaded consequential heads; projection of future earnings (multiplicand and multiplier); inclusion of non‑earnings items; deduction for tax; effect of Workers Compensation payments.
21 September 2017
Employer lawfully terminated by contractual notice; courts may only probe motives where malice is shown.
  • Employment law — termination by notice — exercising contractual notice clause — Industrial and Labour Relations Act s85(5) — when courts may 'pierce the veil' to inquire into motive — requirement of evidence of malice for probing terminations.
19 September 2017
Leave to appeal out of time and a stay of execution were refused for lack of prospects and insufficient evidence to set aside the writ.
  • Civil procedure — Extension of time — Order XIII Rule 3 — Discretionary grant requires sufficient reason and prospect of success; Appeal — Leave to appeal out of time — court may preview merits; Stay of execution — dependent on successful extension of time; Mortgage foreclosure — writ of possession — absence of prima facie ground to set aside; Erroneous advice by former counsel not dispositive.
15 September 2017
Taxation of costs was premature pending conclusion of the appeal; 2017 costs order not retrospective; High Court certification rule inapplicable to Court of Appeal.
  • Civil procedure — taxation of costs — interlocutory taxation; Costs — Legal Practitioners (Costs) Order — retrospective effect; Costs — certification for multiple counsel — application to High Court scales; Court of Appeal jurisdiction — Order XII Rule 1 and Order 62 RSC.
15 September 2017
Bank negligent for encashing crossed cheques to customer’s agent; not liable for a non‑apparent altered cheque; net recovery reduced to ZMW13,182.64.
  • Banker–customer duty; crossed cheques paid contrary to crossing; negligence for paying third‑party cheques to customer’s agent; apparent alterations to cheques; effect of payment into court; proof and pleading of special damages (statutory penalties).
14 September 2017
Defective trial judgment and unresolved credibility on confession evidence warrant setting aside convictions and ordering retrial.
  • Criminal procedure — Judgment writing — Section 169 Criminal Procedure Code — necessity for review of evidence, findings of fact, reasoning and application of law; Evidence — admissibility and weight of warn-and-caution/confession statements; Appeal — when retrial should be ordered where trial judgment is defective and credibility disputed.
14 September 2017
Whether a request to be "released of responsibilities and liabilities" constituted resignation requiring registry changes under the Companies Act.
  • Company law — company limited by guarantee — construction of a letter requesting "release of responsibility and liability" as resignation — Sections 19(3)(b) and 210(1) Companies Act — extension of time to file register changes — appellate standard for disturbing factual findings.
14 September 2017
Defective trial judgment and reliance on confession evidence led to quashing of convictions and order for retrial.
  • Criminal procedure — requirements of a judgment — Section 169(1) Criminal Procedure Code — necessity for review of evidence, findings of fact, credibility assessments and application of law.
14 September 2017
Employer not liable for vehicle tax; advances were loans; refund award set aside as unjust enrichment; some benefits upheld.
  • Employment law — Self‑liquidating motor vehicle scheme; characterization of advances as loans; pleading and admissible evidence for repatriation and retention claims; PAYE overpayment and recovery; tax liability on duty‑free vehicle; unjust enrichment; restitutionary remedies; damages for loss of use.
14 September 2017
Employer’s statutory-board dismissal held influenced by ministerial statements; 24 months’ aggravated damages awarded, vehicle and loss-of-use claims succeed.
  • Employment law — wrongful/constructive dismissal — piercing the contractual notice ‘veil’ to ascertain real motive — ministerial statements influencing statutory body’s decision; damages for traumatic and humiliating dismissal (Mpundu damages); entitlement to equal treatment regarding sale of personal-to-holder vehicle; proof required for allowances payable upon presentation of bills.
13 September 2017
Failure to explain the proviso before plea is curable if explained before witnesses are called and no prejudice results.
  • Criminal procedure — Defilement charge — Proviso to s.138 Penal Code — Duty to explain proviso to unrepresented accused — Failure to explain before plea an irregularity curable if no prejudice — Explanation given before witnesses called cured irregularity.
7 September 2017
A discontinuance of proceedings vacates pending appeals, rendering procedural challenges moot.
  • Civil procedure — Discontinuance of action — Effect of notice of discontinuance vacating pending appeal; procedural issues on affidavit jurat and placement of penal notice left undetermined.
7 September 2017
Whether the appellants were bound by post-judgment consent orders and entitled to assessment of dues under the original judgment.
  • Civil procedure — post-judgment consent orders — binding effect only on parties and their duly authorised agents; Evidence — proof of payment requires proof of receipt by creditor or authorised agent; Assessment of post-judgment dues –Registrar to assess where claimants are not bound by consent orders and no proof of payment; Remittal to Registrar where documentary record is voluminous.
7 September 2017
Appellate court reduced sentence, finding charge duplicitous and sentencing misdirected by reliance on unconvicted multiple acts.
  • Criminal law — Defilement — Duplicitous charge where multiple occasions alleged in a single count — separate acts constitute separate offences (Criminal Procedure Code s.135) — sentencing: age of victim borderline, breach of trust and pregnancy aggravating — sentencing must not reflect unconvicted acts.
7 September 2017