Court of Appeal of Zambia - 2018 November

13 judgments
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13 judgments
Citation
Judgment date
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