Court of Appeal of Zambia - 2019 October

23 judgments
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23 judgments
Citation
Judgment date
October 2019
Court refused to interpret its judgment under Order 6 because an appeal to the Supreme Court was intended, dismissing the application.
Civil procedure — Interpretation of court judgments — Order 6 Court of Appeal Rules — Court declines to interpret its judgment where an appeal is intended — Application dismissed, no costs.
28 October 2019
An appellate court allowed an appeal where the trial judge substituted an un‑pleaded breach of confidentiality claim and reporting was mandated by a Bank of Zambia directive.
Civil procedure – pleadings define cause of action; submissions cannot introduce un‑pleaded causes; banking confidentiality – Bank of Zambia directive (2008) mandates credit reporting, invoking s.50(1)(c) and obviating express consent; factual finding of default supported by evidence.
25 October 2019
Whether confession and corroborative independent evidence removed reasonable doubt to sustain a murder conviction.
Criminal law – murder – circumstantial evidence versus confession – suspect witnesses and danger of false implication – corroboration – admissibility of confessions to non‑authorities (village headman/neighbour).
25 October 2019
Where a claimant adduces uncontradicted courtroom evidence of negligence, absent any rebuttal, liability may be established on a balance of probabilities.
Civil liability – motor collision – pleading versus evidence – pleadings define issues but are not evidence; prima facie case shifts burden to defendants to rebut; failure to call evidence entitles claimant to succeed on balance of probabilities; damages under Fatal Accidents Act and Law Reform Act.
25 October 2019
Appeal dismissed: circumstantial evidence and relatives' testimony upheld where "something more" showed only inference of guilt.
Criminal law — Suspect witnesses — Relatives of victim not automatically suspect; court must assess bias before requiring corroboration; uncorroborated relative testimony may suffice if no danger of false implication. Circumstantial evidence — conviction permissible only where evidence is cogent and permits only inference of guilt; "odd coincidences" or "something more" may corroborate. Appellate review — findings of fact by trial judge not disturbed unless perverse or unsupported by evidence
25 October 2019
Reorganisation changing reporting lines did not amount to demotion or constructive dismissal absent contract breach or pleaded/proved relief.
Employment law — Constructive dismissal; unilateral variation of contract; demotion (change in reporting lines and loss of committee membership); necessity of pleading and proving specific reliefs; evidence and contract terms; costs.
25 October 2019
Belief in witchcraft, without reasonable fear of immediate danger, does not excuse murder nor prevent conviction.
Criminal law – Murder – Belief in witchcraft and provocation/extenuation – Requirement of reasonable fear of immediate danger – Suspect witnesses – relatives not automatically requiring corroboration; danger of false implication must be assessed.
25 October 2019
Appeal dismissed: identification evidence by known witnesses and post-mortems were sufficient to uphold convictions and sentences.
Criminal law – Identification evidence and recognition – witnesses who knew accused – reliability at dusk/traumatic scenes; Suspect witness and possible interest to serve; Corroboration and appellate review of credibility; Post-mortem reports as proof of cause of death; Common purpose and malice aforethought in group attacks.
25 October 2019
Employer's abusive conduct and failure to investigate grievance breached implied trust, amounting to constructive dismissal of the respondent.
Constructive dismissal – implied term of mutual trust and confidence – failure to investigate grievance – 'last straw' principle – burden of proof and failure to call key witness – costs under Industrial and Labour Relations Act Rule 44(1).
25 October 2019
Appeal dismissed: circumstantial evidence, possession of victim’s phone and flight justified inference of guilt.
Criminal law – circumstantial evidence – inference of guilt – last seen evidence – possession of victim’s property – attempt to flee – appellate review of credibility findings.
25 October 2019
Single-witness identification upheld with corroborative threats; defective voire dire on juvenile evidence was harmless; convictions and sentences affirmed.
Criminal law – identification evidence – single identifying witness and corroboration; Juveniles Act s.122 – voire dire and reception of child evidence; alibi – duty to raise and investigate; sentencing – appellate interference only if sense of shock.
25 October 2019
Appeal dismissed: identification and ownership proved despite unregistered brand; High Court rightly overturned magistrate's acquittal.
Criminal law – stock theft – identification evidence and suspect witnesses – caution against false implication – appellate review of perverse findings; Animal Identification Act – registered brand mark presumption vs. other proof of ownership.
25 October 2019
Service charge under the Tourism Act is applied to the net bill after statutory deductions; appellants failed to prove underpayment.
Tourism and Hospitality Act s54 – Service charge computation – gross invoice versus net bill after statutory outgoings (VAT, levies); scope of "tourism-related services" – ministerial prescription required; burden of proof for underpayment; appellate review of factual sufficiency.
23 October 2019
23 October 2019
A council's provisional sale offer was withdrawable where ownership had been transferred to a separate water company.
Local government housing sales — Circular No.2 of 1996 (as amended) — provisional offer to sitting tenant — transfer of assets to separate water company — capacity to sell — withdrawal of offers issued in error — ministerial approval and section 67 Local Government Act.
23 October 2019
Appeal dismissed: non-registration of lease not raised below; tenant liable for three months' rent in lieu and appeal costs.
Land law – LeaseRegistration – Requirement to register leases exceeding one year under the Lands and Deeds Registry Act – Effect of non-registration; Civil procedure – Appeal – Issue not raised in the court below cannot be raised on appeal; Tenancy – Rent in lieu of notice – Measure of damages; Security deposit – claim where deposit not paid; Costs – costs follow the event.
23 October 2019
Service charge under the Tourism and Hospitality Act is calculated on the net bill; non‑prescribed tourism activities do not attract it.
Tourism and Hospitality Act s54(1) — interpretation; service charge payable on net bill after statutory outgoings (VAT, levies); Ministerial statutory instrument required to prescribe activities attracting service charge; burden of proof for underpayment.
23 October 2019
Pension claims arising after mediation are not automatically res judicata; consent orders cannot be nullified without an application.
Industrial Relations Court jurisdiction; pension claims and trust property; res judicata and mediation settlements; effect and sanctity of consent orders; nullification only on application; remittal for fresh directions.
23 October 2019
Failed provocation did not negate the murder conviction but amounted to extenuation, reducing the death sentence to 20 years.
Criminal law – Murder – Provocation: elements (act of provocation; loss of self-control; proportionate retaliation) – Excessive retaliation defeats provocation – Failed provocation may amount to extenuation – Sentence reduced from death to 20 years imprisonment with hard labour.
23 October 2019
Appeal dismissed; leave not required for injunction appeals, but ownership cannot be determined at interlocutory stage.
Appeals — interlocutory injunctions — leave to appeal not required (Court of Appeal Act s.23(1)(e)(ii)); Interlocutory relief — American Cyanamid principles — adequacy of damages for land disputes; Judicial practice — previewing prospects of success for stay applications; Procedure — limits on deciding ownership at injunction stage.
22 October 2019
The respondent lacked capacity to sue for the deceased's estate without letters of administration; appeal allowed.
Succession law — capacity to sue — letters of administration (Section 24 Intestate Succession Act); statute on surviving spouse entitlement (Section 9); appellate procedure — issue raised below; misjoinder/non-joinder; Article 118(2)(e) Constitution.
17 October 2019
Court refused leave to appeal and dismissed stay, finding proposed grounds lacked reasonable prospects of success.
Court of Appeal – Leave to appeal to Supreme Court – Section 13 Court of Appeal Act – grant where point of law of public importance or reasonable prospect of success; Civil procedure – Stay of execution – Order 59 Rule 13(2) Rules of Supreme Court – good and compelling reasons required; Employment/contract – voluntary undertaking in dismissal letter – estoppel/resiling from undertaking; Burden of proof – proof of merger/inclusion of allowance into salary.
11 October 2019
Appeal dismissed: covert recordings admissible when tendered by maker; terminations for alleged leaking were wrongful and 24-month damages justified.
Employment law – wrongful termination – delving behind notice clause – covert audio recordings tendered by their maker admissible – interception statute not fatal where maker testifies – damages for malicious termination, 24 months' salary upheld.
9 October 2019