Court of Appeal of Zambia - 2020

130 judgments
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130 judgments
Citation
Judgment date
December 2020
A consent order is ordinarily impeachable only by commencing a fresh action, not by application within the same proceedings.
Civil procedure – consent orders/judgments – impeachment of consent order – proper procedure is commencement of a fresh action; Obiter dicta v ratio – Paluku comments not binding; Functus officio – effect of sealing/endorsement of consent order; Order 42 Rule 5A (White Book) – endorsement/signature issues do not permit setting aside within same cause; Joinder of non‑parties before fresh action.
24 December 2020
Appellant's challenge to arbitral awards dismissed; awards held within arbitration scope and not contrary to public policy.
Arbitration — setting aside arbitral award — scope of submission to arbitration; public policy and ex turpi causa; strict rules of evidence vs substantial compliance; reliance and expectation damages; jurisdiction and arbitrability; intelligent guess quantification of damages.
23 December 2020
Whether a Certificate of Title can be cancelled for alleged fraud, tax under‑declaration, or non‑Zambian ownership eligibility.
Land law — Certificate of Title — Section 33 and 54 Lands and Deeds Registry Act — cancellation only on proved fraud or impropriety; Alleged tax under‑declaration is a matter for ZRA and does not alone invalidate title; Burden of proof on party alleging ineligibility of non‑Zambian purchaser; Admission of additional grounds in heads if respondent had opportunity to contest.
15 December 2020
Change of corporate name does not defeat suit; court should substitute correct corporate name and remit for trial.
Civil procedure – Order 14A RSC – summary determination of question of law; Companies law – change of name does not affect rights or render proceedings defective; Locus standi – proper corporate party and substitution/joinder; High Court inherent jurisdiction to substitute parties rather than dismiss for misjoinder.
14 December 2020
Persons who assume control of trust property can be held personally liable; claims against seized goods must be lodged within five days.
Trusts and trustees – trustee de son tort – personal liability for assuming control of trust property; Execution of judgment – writ of fifa – validity of execution against persons who assumed trustee functions; Civil procedure – Order 42 High Court Rules – interpleader/claims against goods seized by Sheriff – five-day claim period; Corporate personality – separate legal entity of registered trustees; Proof of ownership – brand certificates and timeliness of claims.
10 December 2020
A renewed application permits new matters; Order 33/3 cannot be invoked independently of Order 14A RSC.
Civil procedure — preliminary issue — Order 33/3 RSC not stand-alone; must be read with Order 14A — renewal v. appeal — renewal allows fresh matters.
8 December 2020
In a renewed injunction application, the court held new aspects permissible and dismissed the preliminary objection.
Civil procedure — Court of Appeal — Preliminary objection — Order 33(3) RSC not standalone; must be read with Order 14A — Distinction between renewal and appeal — New material permissible in renewal — Preliminary objection dismissed.
8 December 2020
The appellant's challenge to the Registrar's registration was dismissed for lack of goodwill and insufficient evidence of public confusion.
Company names – Registrar’s discretion under s.37(3) – likelihood of confusion – passing off – requirement of goodwill – sufficiency of evidence of confusion (unproven misdelivery) – distinguishing features in composite names.
6 December 2020
November 2020
Appellant's challenge to defilement conviction dismissed; age, medical evidence and alibi issues found insufficient to overturn conviction.
Criminal law – Defilement – proof of age and penetration – admissibility and sufficiency of medical report without oral evidence of examining doctor – alibi particulars and duty to investigate – effect of minor inconsistencies in prosecution evidence.
20 November 2020
Employer's failure to assess or give reasons made the termination unlawful; 36-month damages reduced to three months.
Employment law – probation and confirmation – employer's duty to assess and notify shortcomings; wrongful/unlawful termination for failure to give reasons/notice (Employment Act s.36); distinction between termination and summary dismissal; assessment of damages for loss of employment – when courts may depart from notice period and appellate interference where award is excessive.
20 November 2020
Procedural defects in the record do not bar a Supreme Court-ordered rehearing; appeals dismissed and matter remitted for substantive hearing.
Appeal from Subordinate Court — Supreme Court order for re-hearing — effect on requirement for leave to appeal; Record of Appeal completeness — Order 44 (Subordinate Court Rules) and Order 47 (High Court Rules); jurisdiction to hear appeal despite missing magistrate's notes; res judicata and prior High Court rulings; joinder of parties; exercise of discretion as to costs.
20 November 2020
Taxing Master must issue a certificate of taxation; absence of certificate invalidates a review application under Order 40/5 HCR.
Civil procedure — Taxation of costs — Taxing Master must tax bill and issue certificate of taxation — Certificate is condition precedent to review under Order 40/5 HCR — No right of appeal in place of review — Taxing Master must refer legal issues to a Judge.
20 November 2020
An illegal sale of deceased's estate (without court authority) is unenforceable, but repayment claims for monies paid remain recoverable.
Intestate Succession Act s19(2) — Sale of estate property without prior court authority renders sale null and void; High Court jurisdiction — illegality does not automatically bar restitution claims; recovery of monies paid under illegal contracts — unjust enrichment principle; pleadings and admissions; costs against legally aided parties.
20 November 2020
Appeal against 45-year sentence for incest dismissed; threats, non-consent and resulting pregnancy were aggravating factors.
Criminal law – Incest – Consent and aggravating factors – Pregnancy as aggravation where intercourse procured by force and threats – Prevalence of offence and deterrent sentencing – Appellate review of sentence (Jutronich three-question test).
20 November 2020
Conviction for defilement quashed because a child under 14 testified without the mandatory voir dire.
Juveniles Act s122 – mandatory voir dire for witnesses under 14; competence to testify; proof of age (parental/best evidence); admissibility of child evidence; defilement conviction; retrial ordered under s16 Court of Appeal Act.
20 November 2020
Whether a mortgagee must account differs between exercising a contractual power of sale and selling after court-ordered foreclosure.
Mortgage law - duty to account; distinction between contractual power of sale and sale after court-ordered foreclosure; leave to appeal—section 13(2) Court of Appeal Act; quantum disputes in foreclosure proceedings.
20 November 2020
Appeal dismissed: writ commencement and commercial classification upheld; tenancy at sufferance and service issues are factual matters for trial.
Civil procedure – mode of commencement – where statute prescribes procedure it must be followed; absent applicable statute writ of summons permissible; commercial action – Order LIII/Rule 1 – inclusion in Commercial List; factual issues (tenancy at sufferance vs caretaking) require trial; service of process properly effected; appeal dismissed.
20 November 2020
A contributor who gives notice to be heard may seek a stay of winding‑up proceedings and referral of shareholder disputes to arbitration.
Companies law – winding up on just and equitable ground – shareholder disputes under shareholders' agreement – arbitration clause – stay of proceedings under s.10 Arbitration Act – locus of contributor who filed notice under s.60(3) Corporate Insolvency Act – arbitrability versus public policy and third‑party creditor interests.
20 November 2020
A taxing officer must halt taxation and refer preliminary legal issues to a judge; costs require an express 'taxation forthwith' order to be taxed early.
Civil procedure — Taxation of costs; Order 62/8 RSC — 'Taxation forthwith' requirement; jurisdiction — taxing officer vs Judge on preliminary issues of law; power to halt taxation and refer issues; quashing irregularly taxed bills.
20 November 2020
Unexplained contemporaneous circumstantial evidence and odd coincidences can sustain murder convictions and common‑purpose liability.
Criminal law – Circumstantial evidence – standard that only one inference be permissible; admissibility of electronic call records – s.8(4) ECT Act certification requirement; odd coincidences as corroboration; common purpose/joint enterprise liability.
19 November 2020
Order 14A dismissal requires a filed defence as notice of intention to defend; a conditional memorandum is insufficient.
Civil procedure – Order 14A applications – mandatory prerequisites – notice of intention to defend requires filing a defence (Order 11 Rule 1); conditional memorandum insufficient – preliminary points of law not to be determined without compliance with procedural requirements.
19 November 2020
Default judgment entered under inapplicable rules set aside; matter remitted for trial, no need to prove defence when entry irregular.
Civil procedure — Default judgment — Irregular entry under wrong High Court Rules (Order 12 Rules 6 & 7) — Order 12 Rule 8 requires plaintiff to proceed as if defendant had appeared — Irregular default judgment can be set aside without proving an arguable defence — Remittal for trial.
19 November 2020
Whether the respondent disclosed a reasonable cause of action challenging distraint of goods under alleged receivership.
Civil procedure — strike out — whether writ discloses reasonable cause of action — "plain and obvious" test; Distress law — landlord's right to distrain versus rights of receiver/floating charge; receivership and priority disputes are substantive issues for trial; abuse of process threshold.
19 November 2020
Whether fatal-accident claims are time-barred where the Law Reform Act substituted a three-year limit for twelve months.
Limitation of actions — Fatal Accidents Act 1846 — Law Reform (Limitation of Actions, Etc) Act — amendment substituting "three years" for "twelve calendar months" — interpretation of statutory time limits — effect on statute-barred defence.
19 November 2020
Appeal dismissed for failing to renew leave for judicial review under Order 53; interlocutory appeal lacked required leave.
Judicial review — leave to apply — Rules of the Supreme Court (Order 53, Order 59) — renewal of leave before Court of Appeal within seven days — appealability of leave refusal; interlocutory orders — leave under s.23(1)(e) Court of Appeal Act; trial judge’s role on leave applications.
19 November 2020
Appellant’s violent assault causing fatal injuries established malice aforethought; provocation defence unavailable and appeal dismissed.
Criminal law – Murder v. manslaughter – malice aforethought – proof by nature and severity of injuries; identification and witness credibility; defence of provocation (ss.205–206 Penal Code) – objective test of proportionality.
19 November 2020
Whether relatives’ uncorroborated identification was safe and whether a belated, unparticularized alibi could be rejected.
Criminal law – Identification by relatives – When relatives’ evidence requires corroboration; Alibi – duty to raise particulars promptly; Warn and caution statements – effect when defence introduces them; Joint enterprise – liability where cumulative assaults cause death.
18 November 2020
Whether non‑matrimonial assets may be considered in post‑divorce property adjustment and maintenance and whether that legal question is suitable for determination under Order 14A.
Family law — Property adjustment and maintenance after divorce — Distinction between matrimonial (family) and non‑matrimonial property — Whether non‑matrimonial assets are distributable — Relevance of income from non‑matrimonial assets to maintenance (s.56 Matrimonial Causes Act) — Order 14A RSC: determination of questions of law without full trial.
17 November 2020
Joinder of a parent company was improper where no evidence showed it contracted with or authorized the subsidiary's actions.
Company law – Separate legal personality; joinder – proper test for joining a parent company; agency – no evidence subsidiary acted on behalf of parent; civil procedure – joinder set aside.
16 November 2020
Explanation of proviso suffices; alibi need not be proved by accused; prosecutrix over 14 permits conviction on uncorroborated evidence.
Criminal law – defilement – alibi: burden to negative an alibi lies with prosecution; trial court must explain proviso to unrepresented accused but need not ensure comprehension. Juveniles Act s122 – no corroboration required for prosecutrix over 14. Corroboration and hearsay – neighbours' statements inadmissible as corroboration; special and compelling grounds may justify conviction on uncorroborated evidence.
13 November 2020
Circumstantial evidence and undisputed postmortem findings supported a murder conviction and death sentence.
Criminal law — Circumstantial evidence — David Zulu test — sufficiency to exclude reasonable doubt; Postmortem evidence — calling pathologist; Murder — malice aforethought; Sentencing — absence of extenuating circumstances; Death penalty upheld.
13 November 2020
Appellant's challenge to a 40-year rape sentence dismissed; victim’s age and brutal conduct justified the severe sentence, ordered concurrent.
Criminal law – Sentencing – Appeal against sentence – Application of Jutronich test – Whether sentence wrong in principle or manifestly excessive – Aggravating factors: victim’s age and brutal conduct – First offender and remorse as mitigating factors – Concurrency of sentences where offences arise from one course of conduct.
13 November 2020
13 November 2020
Applicant's uncorroborated belief in witchcraft did not qualify as an extenuating circumstance; death sentence upheld.
Criminal law – Murder – Extenuating circumstances – Belief in witchcraft must be evidence‑based to amount to provocation; premeditation, forensic evidence and inconsistent testimony may defeat such a defence.
13 November 2020
Court reduced and recalculated damages, applying weekly-rate method adjusted for currency depreciation and requiring viva voce evidence where ordered.
Motor-vehicle negligence; assessment of damages — pain and suffering (weekly tariff v lump sum) — adjustment for currency depreciation — loss of expectation of life — loss of dependency — requirement for viva voce evidence at assessment.
6 November 2020
Whether extension of time and a stay of execution should be granted pending appeal where delay was caused by COVID‑19 and an arguable defence exists.
Civil procedure — extension of time to appeal — stay of execution pending appeal — maintenance of status quo — amendment of memorandum of appeal permitted — COVID‑19 disruptions as acceptable explanation for delay — no order for payment into court/escrow.
6 November 2020
A default judgment cannot be entered for declaratory relief or while further particulars are pending; triable issues require trial.
Civil procedure — Default judgment — Declaratory relief — Default judgment irregular where declaration sought; pending further and better particulars — court ought to determine particulars before default judgment; setting aside default judgment where triable issues disclosed and reasonable explanation for delay.
4 November 2020
An arbitral award will not be set aside for fraud absent distinct, material proof and a causal effect on the award.
Arbitration — Setting aside award — Fraud, misrepresentation or serious irregularity — High/heightened burden of proof and causative link required; waiver and failure to produce evidence at arbitration preclude later challenge; courts will not act as appellate tribunals on merits or quantum.
4 November 2020
A written part-payment acknowledged by the debtor restarts limitation, so the employment claims were not statute-barred.
Limitation of actions – accrual of cause of action – written part-payment/acknowledgement under s.23(4) Limitation Act 1939 – effect on six-year limitation period; res judicata – scope and requirements; jurisdiction – effect of arbitration to which claimant is not party; appellate procedure – issues not raised below not entertained.
4 November 2020
October 2020
The court upheld conviction where the victim's brother proved age; a school register was inadmissible and the proviso defence was inapplicable.
Criminal law – Defilement (s.138(1) Penal Code) – Proof of age as essential ingredient; Evidence Act – admissibility of official records (school register) – requirement that supplier have personal knowledge; Proviso defence – reasonable belief as to age – not available where accused denies the act; Appeal – sufficiency and credibility of evidence.
23 October 2020
Appellant's defilement conviction and 25-year sentence upheld; opportunity evidence corroborated identity.
Criminal law – Defilement – Proof of age and sexual intercourse – Corroboration by opportunity – Credibility and alibi – Appellate deference to trial findings – Sentence review.
23 October 2020
Superior-court stay maintained status quo; parallel application in High Court found abusive despite High Court having jurisdiction over enforcement matters.
Civil procedure — enforcement — Writ of Fieri Facias — stay of execution — abuse of court process where superior court stay already in place — jurisdiction of High Court to entertain enforcement matters.
23 October 2020
Whether pursuing multiple stays of execution in different courts to restrain enforcement of the same judgment amounts to abuse of process.
Enforcement — stay of execution — jurisdiction of High Court to entertain enforcement matters arising from appellate judgments; Abuse of process — multiplicity of actions and forum shopping where multiple stays sought over same judgment; Fieri facias — endorsement of interest where judgment specifies principal and rate; Appellate review — distinguishing mere background statements from findings of fact.
23 October 2020
Superior-court stay rendered the High Court application to stay execution an abuse of process; interest endorsement followed the judgment.
Civil procedure – enforcement of judgment – stay of execution – effect of superior court stay; writ of fieri facias – endorsement of interest where judgment specifies principal, rate and period; abuse of process – forum shopping and multiplicity of proceedings.
23 October 2020
VAT on settlement capital is not chargeable where a finance lease is terminated by accidental destruction; appeal dismissed.
VAT – finance lease – settlement capital – termination by accident; supply of services for VAT purposes; insurance payout; bank–customer duties; improper crediting between lease accounts; unjust enrichment; damages for breach of contract; reconciliation of lease accounts.
23 October 2020
Dispute over bill of lading amendment and unauthorized transshipment: both breached, appellant liable for loss; counterclaim dismissed.
Bill of lading amendment — timing and control; pre-clearance of customs release; unauthorized transshipment; breach of contract; proof of special damages; costs follow the event.
22 October 2020
Res judicata does not bar subsequent ongoing transactions; the respondent's unsigned reconciliation did not revive a time‑barred claim.
Civil procedure — res judicata — doctrine applies only to matters actually litigated or capable of being litigated in prior proceedings; ongoing subsequent transactions not disputed are not barred. Limitation — acknowledgment of debt — section 23(4) Limitation Act 1939 requires a written and signed acknowledgment; unsigned reconciliation statements do not restart limitation period. Result: claims for October 2011–July 2012 held time‑barred.
22 October 2020
Court upheld first appellant's convictions on cogent circumstantial evidence but quashed second appellant's conviction for lack of corroboration.
Criminal law — murder and aggravated robbery — circumstantial evidence considered collectively; accomplice (suspect) witness requires corroboration; alleged confession must be corroborated; leading police to recovery of weapon does not alone establish culpability.
15 October 2020
Whether cumulative circumstantial evidence sustained the first appellant's convictions and whether the second appellant's alleged confession was corroborated.
Criminal law – Circumstantial evidence – cogency and cumulative assessment; corroboration of suspect/accomplice witnesses; proof of possession/robbery; admissibility/weight of alleged confessions.
15 October 2020
September 2020
Leave granted to judicially review Ministerial common-carrier declaration and ERB interim wheeling tariff; stay refused.
Judicial review — Leave to apply — Ministerial declaration of transmission/distribution lines as common carrier (Electricity Act s.15) — Interim wheeling tariff by ERB — Alternative remedies and appeal routes — Abuse of process — Locus standi — Arguable case (illegality, procedural impropriety, improper motive) — Stay refused.
29 September 2020