Court of Appeal of Zambia - 2021 November

42 judgments
Skip past years
Skip past months
Skip to results

Results. 42 judgments found.

42 judgments
November 2021
Court allowed typographical amendment to appeal documents and ordered costs in the cause.
  • Civil procedure — Court of Appeal Rules, Order VIII — amendment of process before conclusion of hearing; typographical correction to Notice and Memorandum of Appeal; no prejudice; costs in the cause.
30 November 2021
Applicant granted 14‑day extension to file Record of Appeal due to lower‑court administrative delay; no order as to costs.
  • Court of Appeal Rules — Order X Rule 6(a) — sixty‑day period for lodging Record of Appeal; Order XIII Rule 3 — discretionary extension of time for "sufficient reason"; administrative delay in lower court registry; extension of time granted; no costs.
30 November 2021
Court upholds civil non-conviction forfeiture: vehicle used in offence was tainted and claimant lacked sufficient interest to resist forfeiture.
  • Forfeiture of proceeds of crime — non-conviction civil forfeiture under ss.29–31 FPOCA — jurisdiction and mode of commencement — definition of tainted property — claimant’s sufficient legal or equitable interest and onus under s.31(2).
30 November 2021
A court may not sua sponte review and set aside its judgment without timely application, fresh evidence, and hearing of the parties.
  • Civil procedure — Review of judgment — Order 39 High Court Rules — Time limit (14 days) and requirement of leave — Review sua sponte — Need for application and hearing — Fresh evidence requirement — Wrongful execution cause of action.
30 November 2021
A signed third‑party mortgage with continuing‑security clauses constituted express consent to secure subsequent loans.
  • Mortgage law — third‑party mortgage — continuing security clause — express consent by mortgagor — deposit of title deeds creates enforceable security — sanctity of contract — costs follow the event.
26 November 2021
25 November 2021
Claim for indemnity by an auctioneer barred by res judicata after earlier judgment finding it a contracting party, appeal dismissed.
  • Civil procedure — Res judicata — Earlier final adjudication of principal-agent relationship — Auctioneer liability — Abuse of process by relitigation — Indemnity claim arising after compliance with judgment.
25 November 2021
Failure to give mandatory one-month notice rendered the inquiry order void for want of jurisdiction; appeal allowed.
  • Procedure — Order 2 Rule 3 HCR — mandatory one-month notice to proceed after one year’s dormancy — failure deprives court of jurisdiction; Nullity — decisions made without jurisdiction are void; Registrar’s powers — Order 39 R.1 review limited to judges, Registrar cannot review own decision; Appeals — appellate court may consider jurisdictional point of law not raised below.
25 November 2021
Applications for leave to appeal out of time and for a stay dismissed for delay and lack of real prospects of success.
  • Civil procedure — Leave to appeal out of time — Court of Appeal Rules (Order X r4(5); Order XIII r3(1)) — Extension requires sufficient reason and consideration of prospects of success; Stay of execution — discretionary, requires good and convincing reasons and balancing prejudice to judgment-creditor.
25 November 2021
The appellant cannot use review to relitigate issues beyond a limited referral; Order 39 review requires fresh material evidence.
  • Intestate Succession Act s19(1)(c)(ii) — administrators’ duty to render account; Review (Order 39 HCR) — requires fresh material evidence; Scope of referral and functus officio — High Court limited to accounting; Res judicata and finality of Court of Appeal judgment.
25 November 2021
Payment in lieu of notice under the collective agreement equals notice; excessive 24‑month damages reduced to three months.
  • Employment law — redundancy — clause 18 POWAGUZ — payment in lieu of notice equals notice; measure of damages for wrongful dismissal — departure from notice period requires evidence and reasons; appellate interference where discretionary award unjustified.
24 November 2021
A guilty plea is equivocal if the statement of facts conflates trafficking and smuggling and omits essential elements, rendering the conviction unsafe.
  • Criminal procedure — guilty plea — statement of facts must disclose all essential elements of the indicted offence; conflation of smuggling and trafficking renders plea equivocal. Substantive law — distinction between smuggling (section 9) and trafficking (section 3) under the Anti‑Human Trafficking Act; elements and penalties differ
  • Remedy — conviction unsafe; retrial ordered
19 November 2021
Appellate court upheld conviction where corroborated circumstantial evidence and odd coincidence excluded mistaken identity.
  • Criminal law — Aggravated robbery — Identification and mistaken identity — Circumstantial evidence and doctrine of odd coincidence — Credibility findings of trial court — Appellate restraint on factual findings.
19 November 2021
Single-witness identification unsafe; third appellant guilty on circumstantial evidence but armed element unproven, sentence reduced.
  • Criminal law — identification evidence — single identifying witness — dangers of mistaken identification and need for connecting link or corroboration; Identification parade — fairness and conduct; Circumstantial evidence — odd coincidences and inference of guilt; Armed aggravated robbery — requirement for direct evidence of firearm use or recovery; Sentencing — reduction where armed element unproven.
19 November 2021
Appeal against a 35‑year sentence for repeated defilement of a 10‑year‑old dismissed; sentence upheld despite conviction on an improperly duplicated count.
  • Criminal law — Defilement — sentence — appeal against sentence — principles for interference; aggravating factors (young age, breach of trust, repeated acts); corroboration and evidence of opportunity; charging multiple counts for repeated acts.
19 November 2021
A plea asserting belief in the child's age is not evidence; accused must adduce defence evidence, and sentence reduced to 25 years.
  • Criminal law — Defilement (s.138 Penal Code) — Proviso: reasonable cause and actual belief as to age — Plea versus defence evidence — Plea alone is not evidence — Accused must present defence evidence to invoke proviso — Conviction upheld where age, intercourse and identity proved — Sentence reduced from 35 to 25 years for excessiveness.
18 November 2021
Whether a juvenile's identification requires strict corroboration or may be supported by 'something more' (odd coincidences).
  • Criminal law — Defilement — Evidence of juvenile witness — Corroboration under s122(b) Juveniles Act — 'Something more'/'odd coincidences' may satisfy corroboration — Admissions by accused as corroboration.
18 November 2021
Trafficking conviction quashed for lack of admissible confession and proof of weight; convicted of unlawful possession.
  • Criminal law — Trafficking v possession — requirement to prove statutory weight threshold; Admissibility of confessions — accused must be asked if he objects before production; Circumstantial evidence — similarity of packaging must be particularized; Appellate review of factual findings — exceptions to upsetting credibility findings.
18 November 2021
Conviction based on uncorroborated identification by a child under 14, observed at night, is unsafe and quashed.
  • Criminal law — defilement — identification by single witness — corroboration required for witnesses under 14 (Section 122 Juveniles Act) — opportunity for observation and danger of honest mistake — conviction unsafe if uncorroborated.
18 November 2021
Appeal succeeds where sentence was wrong in principle and hard labour for a female first offender was inappropriate.
  • Criminal law — Sentencing — Plea of guilty and first-offender mitigation — Appellate interference where sentence wrong in principle or manifestly excessive — Misdirection by treating grievous harm as attempted murder — Hard labour inappropriate for female prisoners.
18 November 2021
Appeal against a 65-year manslaughter sentence dismissed; aggravating spousal-killing conduct justified heavy sentence.
  • Criminal law — Sentencing — Manslaughter — appellate review of sentence — aggravating factors (domestic assault, luring, strangulation, concealment) — principles for interference (wrong in principle, manifest excess, exceptional circumstances) — precedents on sentencing distinguished.
18 November 2021
Appeal against defilement conviction and 35-year sentence dismissed; minor's alleged consent not mitigating and pregnancy aggravates.
  • Criminal law — Defilement — sufficiency of defence explanation; Sentencing — duty to give reasons; aggravating factors: minor's pregnancy and attempted suppression; minors cannot legally consent.
18 November 2021
Conviction overturned where single interested witness lacked corroboration and trial judge misdirected on reliability of her evidence.
  • Criminal law — murder conviction based on single witness with possible interest — requirement for corroboration or "something more" — failure to direct on witness' interest a serious misdirection — direct vs circumstantial evidence.
16 November 2021
Age is an essential element of defilement and must be strictly proved; medical/tactical ocular observation alone is insufficient.
  • Criminal law — defilement — age as essential ingredient — requirement of strict proof by parents/guardian or best evidence; medical evidence (Tanner staging) requires explanation and cannot alone fix age in borderline cases; ocular observation and misuse of Juveniles Act s.118 in determining age; corroboration of identity where accused found with prosecutrix and medical evidence of penetration.
16 November 2021
Voluntary drinking does not automatically mitigate murder; trial court’s finding of lack of extenuation upheld and convictions confirmed.
  • Criminal law — murder — intoxication as mitigation versus intoxication as defence — Section 201(2) Penal Code — drinking alone does not automatically amount to extenuation — appellate deference to trial court's findings of sobriety and intent.
16 November 2021
Conviction quashed where circumstantial evidence failed to exclude a reasonable innocent explanation for recent possession.
  • Criminal law — Stock theft — Circumstantial evidence — Recent possession — Innocent receiver/mistake of fact (s.10 Penal Code) — Drawing inferences; where multiple inferences possible adopt one favourable to accused.
16 November 2021
Appeal dismissed: corroboration and 'something more' found; conviction for defilement and 30-year sentence upheld.
  • Criminal law — Defilement — Corroboration under Juveniles Act s.122 — Voir dire and age threshold — Witnesses related to victim and danger of false implication — "Something more"/special and compelling grounds — Sentence upheld.
16 November 2021
Termination under a written contract by payment in lieu is lawful without a disciplinary hearing if contract terms are followed.
  • Employment law — Termination of employment — Written contract — Applicability of section 26A (repealed Employment Act) to oral contracts only — Termination by payment in lieu of notice lawful if contract permits — Distinction between dismissal (disciplinary) and contractual termination.
11 November 2021
Claim for refund barred as res judicata and time‑barred; alleged late discovery of fraud did not extend limitation.
  • Civil procedure — Res judicata; multiplicity of actions; abuse of court process — Limitation Act 1939 — mortgage deed as specialty (12‑year limitation) — s.26 (fraud discovery) not applicable where fraud was discoverable earlier.
11 November 2021
Refusal to adjourn was within discretion; purchaser from a fraudster did not acquire good title, so title cancelled and property reverted to the estate.
  • Property law — nemo dat quod non habet — purchaser cannot acquire good title from a fraudster; Land registry — forged title and advertisement do not validate title; Civil procedure — discretion to refuse adjournment; Intestate succession — Administrator General’s sale of estate property and requirement for court order.
10 November 2021
Administrator's sale and title upheld; fraud not proved to the higher civil standard, appeal dismissed with costs.
  • Conveyancing and land titles — Certificate of Title conclusive of ownership save for fraud — Allegations of fraud must be clearly pleaded and proved to a higher civil standard — Administrator's capacity to assign land — Consolidation and substitution of parties in proceedings.
9 November 2021
Retention on payroll under a collective agreement precludes entitlement to interest on delayed retirement benefits.
  • Employment law — retirement benefits — Collective Agreement Clause 28.2 — retention on payroll and payment of salaries — entitlement to interest — unjust enrichment — Order 14A determination of question of law — persuasive precedent (Iness Zeko).
8 November 2021
Retirees paid salaries pending gratuity are not entitled to interest because salaries compensated delay, avoiding unjust enrichment.
  • Employment law — retirement gratuity — clause providing salary continuation until gratuity paid — entitlement to interest; Order 14A — determination of questions of law without full trial; unjust enrichment/double payment; persuasive precedent (Iness Zeko); right to be heard — affidavit procedure.
8 November 2021
Whether an Order 14A application is competent where respondents filed only a conditional memorandum without a defence.
  • Civil procedure — conditional memorandum of appearance — Deputy Registrar endorsement — 14-day period for intended application; Order 14A RSC — prerequisites — notice of intention to defend requires memorandum plus defence; Order 11 r.1(4) HCR — proper route to set aside writ for irregularity; jurisdiction — incompetence of proceedings renders orders null and void; remittal to High Court.
5 November 2021
A notice to raise preliminary issues is not a notice to defend; joinder after dismissal and charging a settlement require proper legal basis.
  • Civil procedure — Order 14A RSC — notice of intention to defend requires memorandum of appearance and defence; preliminary issues notice insufficient; joinder after dismissal and effect of deed of novation; charging order requires proof of judgment debtor's beneficial interest.
5 November 2021
Conditional appearance prevents entry of default judgment while time to apply to set aside the writ or to file a defence subsists.
  • Civil procedure — conditional appearance — effect on time to enter defence or to apply to set aside writ — plaintiff prohibited from entering default judgment during period for appearance; irregular default judgment; requirement to show defence on merits not applicable where default is irregular.
5 November 2021
Whether a court can lift its own stay and supervise a suo motu referral to arbitration when arbitration becomes impracticable.
  • Arbitration clause — sua sponte referral to arbitration — stay of proceedings — inherent jurisdiction to control court proceedings — lifting a stay where arbitration fails — joinder of assignee plaintiff — interlocutory relief versus appeal.
5 November 2021
Joinder allowed: striking out a joint-venturer was premature pending interrogation of the joint venture agreement.
  • Civil procedure — Joinder of parties (Order 15 Rule 6; Order 14 Rule 6) — Joint venture v partnership — Privity of contract — Whether a joint-venturer may be joined where its agreement may affect the rights of litigants.
5 November 2021
Invoking Order 14A without a memorandum of appearance accompanied by a defence is procedurally incompetent and void.
  • Civil procedure — Competence of applications under Order 14A RSC; conditional memorandum of appearance — Deputy Registrar endorsement and commencement of limitation period; Order 11 Rule 1(4) HCR as proper route to set aside writ for irregularity; jurisdiction — procedural non‑compliance renders orders null and void; Corporate Insolvency Act — leave requirement (procedural issue addressed below in remitted proceedings).
5 November 2021
Failed joint-venture foundation discharged the land sales; titles revert to the applicant upon restitution.
  • Land and contract law — failed joint venture/ frustration of purpose — destroyed foundation of contract; joint tenancy and severance; cancellation of certificate of title requires proof of fraud/impropriety; evidence of payment/signature disputes; restitution and reversion of land titles.
1 November 2021
Failed joint‑venture foundation discharged land sale contracts; parties restored by restitution and titles cancelled/re‑issued.
  • Land law — Sale of land tied to joint venture — Failed foundation/frustration — Proof of payment and disputed signature — Discharge of contract and restitution — Cancellation and re‑issuance of certificates of title — Joint tenancy/severance issues.
1 November 2021
Administrator’s sale of intestate land without prior court authority is void; however the challenge was time‑barred under the Limitation Act.
  • Intestate succession — administrator's power to sell — section 19(2) Intestate Succession Act requires prior court authority; sale without it void — Limitation Act section 2(1) six-year bar for actions on simple contract — summary disposal under Order 14A; plaintiff may not invoke Order 14A to dispose own cause — cancellation of title where transfer void for want of authority; unpleaded equitable claims not entertained on appeal.
1 November 2021