Court of Appeal of Zambia - 2017 March

17 judgments
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Results. 17 judgments found.

17 judgments
March 2017
An accidental open fracture leading to infection was held the proximate insured cause, making the insurer liable within policy territory.
  • Insurance law — Group personal accident — Proximate cause: open compound fracture permitting infection held operative cause of subsequent sepsis/DIC and amputations — "bodily injury caused by accidental, violent, external and visible means" — chain of causation; Territorial limits of policy; Admissibility and weight of unsworn medical reports vs expert opinion on records.
29 March 2017
Insurer liable where amputations were proximately caused by infection entering through an accidental open fracture occurring within policy territory.
  • Insurance law — proximate cause — accidental bodily injury defined as violent, external and visible means — consequential infection/sepsis and DIC as proximate results of an open fracture — territorial limits of policy; admissibility and weight of expert opinion.
29 March 2017
Late review based on a provisional offer failed: evidence was discoverable earlier and immaterial against a registered title.
  • Civil procedure — Review under Order 39 High Court Rules — Late application and implied leave — Fresh evidence tests (Jamas Milling; Ladd v
  • Marshall) — Discoverability with due diligence — Provisional offer vs. document of title — Abuse of process
29 March 2017
Defective voir dire and inadequate corroboration (including biased relatives and inconclusive medical evidence) led to quashing of incest conviction.
  • Criminal law — Juveniles Act s.122 (as amended) — voir dire requirements — child must be sufficiently intelligent and understand duty to speak truth; Evidence — corroboration required where child’s prosecution evidence admitted — independent corroboration necessary; Relatives as witnesses — potential bias and danger of false implication; Medical evidence — inconclusive report insufficient to corroborate sexual assault allegations; Retrial — not ordered where foundational evidence deficient and retrial would prejudice accused.
21 March 2017
Appeal dismissed: relatives’ uncorroborated evidence can be relied on where inconsistencies do not affect the core offence.
  • Criminal law — arson; identification in daylight; witnesses related to complainant — corroboration not always required; appellate review of credibility and inferences; land dispute as context for crime.
17 March 2017
Identification, corroborated by possession of the getaway vehicle and ballistic evidence, upheld conviction and death sentence under s.294(2).
  • Criminal law — Identification evidence — reliability and corroboration; Common purpose/joint enterprise — liability for acts within scope of design; Corroboration by possession of getaway vehicle and ballistic evidence; Admissibility of alleged admissions — need to test voluntariness; Sentence — aggravated robbery under s.294(2) (firearm) and death penalty.
17 March 2017
Murder convictions unsafe without medical causation evidence and defective voire dire; convictions substituted to assault under s.224(a).
  • Criminal law — causation in homicide — necessity of calling author of post-mortem or medical expert where cause of death is stated as "kwashiorkor with septic burns"; Juveniles Act s.122 — twofold test (intelligence and understanding duty to speak truth) and effect of defective voire dire — discounting child evidence; admissibility of confessions to non-authority family members; appellate substitution of conviction and sentence to lesser offences (s.224(a)).
17 March 2017
Cogent circumstantial evidence and a weapon identified by the appellant sustained the murder conviction despite an inducement-related misdirection.
  • Criminal law — murder; circumstantial evidence — inference must be the only reasonable inference; leading accused to scene — voluntariness/inducement; admissibility of real evidence obtained after impermissible inducement.
17 March 2017
Conviction for armed aggravated robbery unsafe where air pistols weren't firearms and identification relied on clothing and dock ID.
  • Criminal law — Aggravated robbery — distinction between armed and ordinary aggravated robbery — definition of "firearm" excludes ordinary air guns; Identification — dock identification based on clothing without prior parade unsafe; Admissibility — admissions/leading/demonstrations require warn-and-caution and formal confession; Judgment standards — trial judge must evaluate evidence and give reasons per s169 CPC.
17 March 2017
Defective voire dire and lack of independent corroboration rendered the conviction unsafe; appeal allowed and conviction set aside.
  • Criminal law — Incest — Juveniles Act s122 as amended — Voir dire requirements: child must possess sufficient intelligence and understand duty of speaking the truth — unsworn evidence no longer permitted — child evidence requires corroboration — Corroboration: independent material evidence required to establish commission and identity — relatives and interested witnesses may be suspect where motive or custody dispute exists — inconclusive medical reports insufficient corroboration — retrial not ordered where prosecution case lacks requisite corroboration.
17 March 2017
A 30-year sentence for manslaughter was substituted with 5 years where the trial court failed to credit plea and first‑offender mitigation.
  • Criminal law — Sentencing — Manslaughter (maximum life imprisonment) — Requirement to consider plea of guilty and offender's antecedents — Sentences that are manifestly excessive may be substituted — Aggravating factors must be supported by evidence.
16 March 2017
Failure to properly admit an accused's inculpatory statement rendered the murder conviction unsafe; conviction set aside.
  • Criminal law — Murder — Admissibility of accused's incriminating statement — Requirement for warning/caution and trial court inquiry before admitting statement — Confession of co-accused and non-adoption — Circumstantial evidence and safety of conviction — Misdirection leading to setting aside conviction.
16 March 2017
Circumstantial evidence found sufficiently cogent to exclude suicide; conviction and death sentence for murder upheld.
  • Criminal law — Circumstantial evidence — Cogency required to exclude other hypotheses; treatment of relatives as potentially interested witnesses; post-mortem evidence and need for pathologist's oral testimony; malice aforethought and sentencing (death).
16 March 2017
A reliable single identifying witness can sustain a conviction despite a misdirected finding about weapon recovery.
  • Criminal law — identification evidence — single identifying witness — when corroboration is required; witness with possible interest — spouse not automatically biased; misdirection on factual finding regarding weapon recovery.
16 March 2017
Qualified privilege protects communications to interested parties unless express malice is proved; mere lack of verification is insufficient.
  • Defamation — qualified privilege — publication to interested parties — malice required to defeat privilege — failure to verify not per se malice — damages.
7 March 2017
The appellant obtained a 30‑day extension to file the record and heads due to the transcript not being typed.
  • Court of Appeal — Extension of time to file record of appeal — Court of Appeal Rules (Order VII and Order XIII) — untimely transcription of proceedings — application granted — costs in the cause.
2 March 2017
Court granted 60‑day extension to file appeal record and heads, holding res judicata challenge should await the main appeal.
  • Civil procedure — extension of time to file record and heads of argument — sufficient cause — transcript delay and office recess — res judicata objection to be determined in main appeal — discretionary relief granted.
1 March 2017