Court of Appeal of Zambia - 2018

107 judgments
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107 judgments
Citation
Judgment date
December 2018
Stay of execution refused where the lower court's ruling merely set aside a judgment and conferred no executable remedy.
Civil procedure – stay of execution pending appeal – discretionary remedy – only executable judgments/rulings can be stayed – setting aside default judgment not an executable order – considerations: prospects of success and irreparable harm.
23 December 2018
Re-entry without proven service and despite material developments is unjustified; compensation must include land and improvements.
Lands law – re-entry under lease – requirement for notice and proof of service; development threshold for re-entry; compensation — market value of land and improvements; bona fide purchaser and notice.
21 December 2018
Contract terms permitting seizure and sale of pledged collateral on default precluded damages for alleged illegal sale absent timely review.
Contract law – enforcement of written loan agreements – collateral seizure and disposal on default; Civil procedure – interlocutory rulings and review (Order 39 High Court Rules) – functus officio and timely review applications; Remedies – availability of damages for sale of pledged asset where borrower defaulted.
21 December 2018
Failure to erect warning signs for roadworks constituted negligence; unpleaded contributory negligence could not be inferred and appeal dismissed.
Negligence — duty to warn road users of works — failure to erect warning signs; credibility of witnesses and appellate review; contributory negligence unpleaded and no expert evidence on speed; admissibility/weight of police report in civil proceedings.
21 December 2018
Appellate court set aside resulting trust for lack of proof, upheld sale and ordered conditional specific performance.
Land law – Certificate of title – Resulting trust – Presumption arising from payment of purchase money – Need for clear, cogent evidence to establish payment – Specific performance for sale of land – Caveat – Pleading requirements for professional conduct allegations.
14 December 2018
Represented accused’s denial negates prejudice from non‑explanation of section 138 proviso; medical evidence and opportunity corroborated conviction.
Criminal law – Defilement – Section 138 proviso – obligation to explain to accused; represented accused – no prejudice where defence is outright denial – Corroboration in sexual offences – medical evidence and opportunity/relationship may corroborate commission and identity.
14 December 2018
Court upheld stay and mandamus compelling formation of tribunal so statutory appeal rights could be vindicated.
Administrative law – judicial review and mandamus – compelling appointment of members of statutory tribunal – interim relief/stay in aid of mandamus under Order 53(10)(b) – wrong mode of commencement principle distinguished – statutory appeal to tribunal – affected parties and joinder.
14 December 2018
Deputy Registrar’s failure to consider the appellant’s opposing affidavit rendered the assessment unfair; rehearing ordered de novo.
Civil procedure – assessment of damages – duty to consider opposing affidavit – hearing on the merits – judgment not on merits liable to be set aside – de novo rehearing – costs in the cause.
5 December 2018
November 2018
Constructive dismissal requires resignation or notice; appellant awarded salary arrears for working-leave period but not damages or other allowances.
Employment law – constructive dismissal – employee must resign or give notice to claim constructive dismissal; transfer and working-leave disputes; entitlement to salary arrears while on working leave; proof required for contractual allowances and damages; limitation defence must be pleaded or is waived.
29 November 2018
A party likely to be affected by reissued exploration rights ought to be joined under Order 14/5(1) HCR.
Procedure — Joinder of parties — Order 14/5(1) HCR and Order 15/4(1) RSC — person entitled to or claiming interest in the subject matter or likely to be affected — ministerial cancellation and reissuance of petroleum exploration licence — discretion to join aimed at effective adjudication — distinction from Abel Mulenga.
28 November 2018
Whether a registered debenture secured a later US$ facility and whether restructuring and charges after default were lawful.
Contract and security — Mortgage debenture as continuing security for future disbursements; discharge by third-party payment limited to specific title; restructuring of loan/lease agreements after default; entitlement to finance and rental charges on restructured accounts; liability for rentals on damaged assets absent insurer proof; appellate standard — balance of probabilities and deference to trial judge's factual findings.
26 November 2018
Circumstantial evidence and post-mortem findings established guilt; appeal against conviction and sentence dismissed.
Criminal law – circumstantial evidence – sufficiency to exclude reasonable doubt; post-mortem evidence and failure to call pathologist; inference of guilt from concealment and bound body.
22 November 2018
A conditional statutory appointment subject to ministerial approval does not create a binding contract until approval is given.
Statutory condition precedent — ministerial approval for appointments; conditional appointments and contract formation; rescission of conditional appointment; estoppel by representation not available where statutory approval required; administrative duty of appointing board to present single nominee.
22 November 2018
The respondent’s post-trial mineral licence was excluded as irrelevant to the appeal on injunction and full disclosure.
Civil procedure – Admission of new evidence on appeal – Section 24(1)(b)(i) Court of Appeal Act – Test: obtainability with diligence, credibility, material influence (Zambia Revenue Authority v Hi-tech) – Post-trial mineral licence held irrelevant to appeal on injunction and disclosure – Injunctive relief against statutory planning authority.
21 November 2018
Force used after the theft to flee did not satisfy aggravated robbery; convictions substituted to assault and burglary.
Criminal law – Aggravated robbery – contemporaneity and purpose of force – force used to flee not to obtain/retain – substitution under s.181(2) Criminal Procedure Code to assault occasioning actual bodily harm and burglary.
20 November 2018
A brutal murder despite failed provocation can justify life imprisonment despite the appellant being a first offender.
Criminal law – Murder with extenuating circumstances – Failed provocation – Sentencing principles – Life imprisonment – Aggravating brutality – Causation: stab wounds to septicemia.
20 November 2018
Circumstantial evidence found sufficiently cogent to uphold murder conviction; infanticide and procedural complaints failed.
Criminal law – Circumstantial evidence – Sufficiency and cogency of cumulative strands; Murder (s.204) vs. Infanticide (s.203); voluntariness of confession and police investigative omissions.
20 November 2018
Whether the trial court exercised its discretion judicially under section 129 in refusing forfeiture of the appellant's vehicle.
Environmental Management Act s129(1) – Forfeiture of vehicles used in offences – Scope and limits of judicial discretion; requirement to give reasons; appellate review for capricious exercise of discretion; Penal Code s28(d) – limits on default custodial terms.
20 November 2018
Earlier explanation of the statutory proviso sufficed; conviction upheld on overwhelming evidence.
Criminal law — Defilement (s138(1) Penal Code) — Proviso (reasonable belief as to age) — Requirement to explain proviso — Confession and medical corroboration — Adequacy of trial judgment (s169 Criminal Procedure Code).
20 November 2018
Appeal against murder conviction dismissed; provocation defence not established and asserted condom‑claim was an afterthought.
Criminal law — Murder — Defence of provocation — Elements required under Sections 205 and 206 Penal Code — provocative act, loss of self‑control, proportionality — reasonable person test — afterthought defence inadmissible.
20 November 2018
Whether correspondence or conduct can restart the six-year limitation period or estop a defendant from pleading time-bar.
'Limitation of Actions' – six-year period under section 2(1)(a); 'Fresh accrual' – sections 23 and 24 require a clear written acknowledgement or part payment; 'Without prejudice' correspondence inadmissible as acknowledgement; 'Negotiations' do not stop limitation; 'Acquiescence/Estoppel' requires clear conduct inducing delay.
1 November 2018
October 2018
Belief in witchcraft and intoxication do not automatically mitigate murder to avoid the death penalty.
Criminal law – Murder – Sentencing – Extenuating circumstances – Belief in witchcraft – Drunkenness – Supreme Court’s refinement in ABEDINEGO KAPESHI – Mandatory death penalty upheld where no mitigating impairment or genuine belief motive established.
20 October 2018
Conviction upheld where single witness reliably identified appellants; identification parade fair and alibi rejected as afterthought.
Criminal law – Aggravated robbery – Conviction on single identifying witness – Reliability of identification (opportunity, lighting, duration) – Fairness of identification parade and pre‑exposure – Alibi raised late and uncorroborated – Appeal dismissed.
15 October 2018
Application to vary dismissal for late service of appeal denied; consolidation application does not cure procedural default.
Civil procedure — Court of Appeal Rules — service of notice and memorandum of appeal within prescribed time — Order 10 Rule 3(9) — consolidation application does not stop time running — Article 118(2) Constitution not a licence to disregard procedural rules — sanction for non-compliance.
11 October 2018
Non-compliance with service rule not automatically fatal; court may exercise discretion or deem waiver to cure default.
Civil procedure – Court of Appeal Rules Order 10/3(9) – service of notice of appeal and memorandum within 14 days – mandatory wording not necessarily fatal – relief and discretion under Order 13/3 – power to direct service under Order 10/9(12) – waiver by filing response – prejudice assessment.
4 October 2018
Building on another's land due to a mistaken allocation does not create title; a sitting tenant who purchased during privatization was a bona fide purchaser.
/ Property law – Construction on another's land – Mistaken allocation by a third party does not confer title; / Bona fide purchaser for value – Sitting tenant offered sale during privatization entitled to purchase absent notice; / Formalities and privatization – Asset transfer to privatization agency controls alienation; / Equitable relief/compensation – Building at own risk; compensation against government may be ex gratia.
4 October 2018
Assessment awards set aside where Deputy Registrar made unexplained, unsupported awards without oral evidence.
Damages assessment — Law Reform (Miscellaneous) Provisions Act — loss of expectation of life — funeral expenses — non-pecuniary damages (stress/anguish) — necessity of oral evidence at assessment — requirement for reasons and evidential basis for awards — appellate interference where assessment unsupported.
4 October 2018
An extension of time was refused where the applicant failed to produce sufficient documentary evidence justifying the delay.
Civil procedure – Extension of time – Order XIII Rule 3(1) – Exercise of judicial discretion – Need for sufficient and convincing reasons supported by documentary evidence (board resolution/minutes) – Short delay insufficient to cure lack of material.
3 October 2018
Whether seized properties belonged to the appellant and whether the claimant discharged the burden of proof.
Civil procedure – execution of judgment – writ of possession – claimant’s burden to prove title or right to possession at time of seizure – distinction between municipal house numbers and Ministry of Lands plot numbers – equity of redemption vs. assignee of debt and security – third-party ownership claims.
3 October 2018
Claimant failed to prove ownership of one seized house but held sufficient equitable interest in another, warranting its release.
Civil procedure – execution and writs of possession – burden of proof on claimant to show title or right to possession at time of seizure; distinction between street/house numbers and Ministry of Lands plot/stand numbers; mortgage, assignment of debt/security and equity of redemption – assignment of debt/security not equivalent to transfer of property.
3 October 2018
3 October 2018
Operations manager lacked authority to amend contract; BIT allowance offsets deductions (applies to empties); re‑computation and assessment ordered.
Contract law — agency and apparent authority — ratification; Contract interpretation — BIT (Missing and Breakage in Transit) allowance — contextual/commercial construction; whether allowance is monetary or an offset; application to fulls and empties; waiver and withdrawal of waiver; assessment of disputed deductions and advances; costs awarded to successful appellant.
3 October 2018
A defective consolidated record of appeal is curable; dismissal is discretionary and depends on the defects' seriousness.
Court of Appeal rules – record of appeal – Order 10/9 mandatory contents – Order 10/17(1)-(2) discretion to amend or dismiss – consolidated appeals – curable versus fatal defects – supplementary record of appeal.
3 October 2018
Respondent's pension to be recalculated from actual retirement date; government-debt deduction upheld; quantum referred for assessment.
Pensions law – effective date of retirement – calculation of pension benefits using last drawn salary (section 40(1)) – government debt deduction under section 22(2)(b) – referral to Deputy Registrar for assessment.
3 October 2018
September 2018
Appeal dismissed: confessions to a lay witness were voluntary and recovered exhibits plus phone-tracing sufficiently proved the offences.
Criminal law — admissibility and voluntariness of confessions — person in authority; Identification and circumstantial evidence — tracing of stolen property and recovery of exhibits as proof of guilt; sufficiency of evidence for rape, attempted rape and aggravated robbery.
27 September 2018
Circumstantial facts (vehicle possession, abandoned car and keys, failure to report) were sufficiently cogent to uphold conviction.
Criminal law – Circumstantial evidence – Cogency required to exclude conjecture – Possession and unexplained failure to report vehicle found abandoned near crime scene as basis for inference of participation.
25 September 2018
An undefended matrimonial petition still requires oral evidence; trial court erred dispensing with trial and making findings.
Matrimonial law – Proof of petition – Rule 37 requires oral evidence in open court – Undefended petition does not dispense with petitioner's duty to prove allegations – Trial judge erred in dispensing with trial and entering findings without evidence – Appeal allowed and matter remitted for trial.
21 September 2018
A single judge may validly sit in the Industrial Relations Division; employers must give reasons for dismissals and 12‑month damages upheld.
Industrial Relations Division — court composition after constitutional amendment — Article 135 permits single judge; Industrial Relations Court Rules (SI 206 of 1974) remain applicable — Employment Act s36(1)(c)(i) & s36(3) — employer must give valid reasons for dismissal; notice clauses cannot avoid statutory duty — wrongful dismissal damages; measure and appellate restraint.
17 September 2018
Appeal dismissed: no special circumstances for security for costs; advocates found to have valid retainer and affidavit proper for factual findings.
Civil procedure — Security for costs — Discretion and ‘special circumstances’ — Affidavit relied on for discretionary factual findings — Right to be heard — Legal Practitioners Act s.52 — Retainer and instructions to counsel.
6 September 2018
August 2018
Whether the employer's disciplinary code applied and whether dismissals for protesting bonus withdrawal were lawful.
Employment law — disciplinary code authentication — unfair dismissal — substitution of charges — 13th cheque as contractual entitlement — group company proceedings — exhaustion of remedies — s101(2) ILRA inapplicable
23 August 2018
The appellant's failed defences did not establish reasonable doubt or constitute extenuating circumstances.
Criminal law – murder – circumstantial evidence; defences – evidential burden to raise defences vs prosecution’s burden to negative them; intoxication; self-defence; provocation; accident; forensic evidence; sentencing – extenuating circumstances.
23 August 2018
Recognition-based identification and joint enterprise upheld; murder conviction affirmed and aggravated robbery sentence increased to life imprisonment.
Criminal law – Identification by recognition – honest mistake – opportunity and lighting; Joint enterprise – section 21(1) Penal Code – principals/accessories; Murder – malice aforethought – section 204(b) – use of offensive weapons; Aggravated robbery – sentence increased to life imprisonment with hard labour.
22 August 2018
Expired tenancies, arrears and lack of capacity meant no clear right or equitable basis for interlocutory injunction; appeal dismissed.
Interlocutory injunctions — American Cyanamid test — requirement of serious question to be tried and clear right to relief — expiry of tenancy agreements; tenancy at will — alleged renewal by conduct — clean hands (rental arrears) — capacity to give undertaking — sale in liquidation and transfer of beneficial interest.
22 August 2018
Recognition identification and joint enterprise proved appellants guilty; aggravated robbery sentence increased to life, murder conviction and death sentence upheld.
Criminal law – Identification by recognition at night – Need to exclude honest mistake – Joint enterprise and liability under section 21(1) – Malice aforethought under section 204 – Sentence substitution for aggravated robbery; death sentence maintained.
22 August 2018
Summary dismissal without a hearing was wrongful; statute obliges employer to repatriate foreign employees despite contractual exclusion.
Employment law – unfair dismissal – breach of natural justice (audi alteram partem) – court may probe mala fides; Immigration Act s28(8) – employer's repatriation obligation overrides contrary contractual clause; mitigation of damages; correction of accrued leave entitlement.
22 August 2018
Terminal gratuity must include the services allowance as last paid (tax gross-up); successful retiree awarded costs.
Employment law – terminal benefits – services allowance – grossing-up for tax – interpretation of conditions of service and HR memorandum; computation of gratuity; costs follow the event – discretion and "no order as to costs".
22 August 2018
Insufficient evidence of a firearm (no recovery or ammunition) precluded conviction under section 294(2); substituted convictions under section 294(1).
Criminal law – Aggravated robbery – Firearm element – Proof required under Firearms Act – recovery of firearm, cartridges or strong circumstantial/forensic evidence; recent possession of stolen property as evidence of guilty knowledge.
21 August 2018
Whether omission to explain a later-enacted proviso or recall witnesses after amending the offence date vitiated a corroborated defilement conviction.
Criminal law – Defilement (s138 Penal Code) – Proviso retrospectivity – Charge amendment and variance as to date (s213(2) Criminal Procedure Code) – Recall of witnesses – Corroboration of prosecutrix by medical report and caution statement – Submissions not evidence – Irrelevance of testing accused for victim's STI.
21 August 2018
Dismissal was wrongful for breach of natural justice; statute mandates reasonable repatriation despite contractual exclusion.
Employment law – wrongful and summary dismissal; natural justice (audi alteram partem) – requirement to afford hearing; court's power to examine substratum of facts/mala fides; Immigration and Deportation Act s28(8) – employer's repatriation obligation overrides contractual exclusion; mitigation of damages; computation of accrued leave.
21 August 2018
A registered certificate of title is conclusive evidence of ownership unless fraud, misdescription, or prior interest is proved; appeal dismissed.
Lands and Deeds Registry Act s33 — registered certificate of title conclusive evidence of ownership; requirements to rebut title (fraud, misdescription, prior interest). Survey law — re‑planning/re‑alignment where newly created lot overlaps earlier surveyed lot. Appellate review — interference with trial findings of fact only where findings are perverse or unsupported. Civil procedure — written submissions are advisory and not binding on the court.
17 August 2018