Court of Appeal of Zambia - 2021 March

21 judgments
Skip past years
Skip past months
Skip to results

Results. 21 judgments found.

21 judgments
March 2021
Court granted extension to file appeal documents due to Covid-19 closures, finding the delay not inordinate.
  • Civil procedure — Extension of time — Court of Appeal Rules, Order 13 Rule 3(1) — Covid-19 related law-firm closures as sufficient reason — inordinate delay — costs awarded.
31 March 2021
Court granted a 21‑day extension to file appeal documents due to COVID‑19 closures, finding delay not inordinate.
  • Court of Appeal Rules (Order 13 Rule 3) — extension of time — sufficient reason — COVID‑19 related closure of law firm — inordinate delay — filing deadline and automatic dismissal.
31 March 2021
Whether a statutory derivative action is available once liquidation commences under the new Companies and Corporate Insolvency Acts.
  • Corporate insolvency — Liquidation — Availability of statutory derivative action post‑liquidation — Interaction between Companies Act s331 and the Corporate Insolvency Act — Leave to appeal — Applicability of Avalon Motors authority.
31 March 2021
Guideline 8(iv) obliges the Secretariat to notify a complainant in writing of refusal to withdraw, but that omission did not prejudice the investigated party.
  • Administrative law — interpretation of regulator's procedural guidelines — Guideline 8(iv) requires Secretariat to inform complainant in writing of refusal to accept withdrawal; duty owed to complainant not investigated party — right to be heard and legitimate expectation not established where investigated party failed to take available opportunities to respond.
31 March 2021
Whether a 30-year sentence for defiling a 12-year-old who became pregnant was excessive despite guilty plea and first‑offender status.
  • Criminal law — defilement — sentencing — first offender and plea of guilty — aggravating factors (victim aged 12, night ambush, mouth covered, resulting pregnancy) — appellate interference standard (wrong in principle or shock) — precedent reliance (Hara).
31 March 2021
Leave to appeal refused: no reasonable prospect or point of law of public importance concerning VAT or breach of contract.
  • Civil procedure — Leave to appeal to Supreme Court (s.13 Court of Appeal Act) — threshold of reasonable prospect and public importance; VAT on settlement following premature termination of lease — interpretation of finance agreement and VAT Act; costs awarded.
31 March 2021
Sections 23–24 of the Companies Act protect third parties and prevent automatic invalidation of proceedings for lack of a board resolution.
  • Company law — capacity and authority to litigate — Sections 23 and 24 Companies Act displace common-law requirement for board resolution; indoor management rule; procedural irregularities — curable vs fatal; interlocutory injunction — prima facie case and irreparable harm.
30 March 2021
Appeal dismissed: vendor withheld title and subdivided land; specific performance and costs awarded to respondents.
  • Contract for sale of land — title delivery versus payment — time of the essence — notice to complete — concealment and subdivision — specific performance and costs.
30 March 2021
Delay of six months and 25 days was inordinate; applicant failed to adequately account, so extension denied with costs.
  • Civil procedure — extension of time — inordinate delay — duty to apply promptly — adequacy of explanation — COVID-19/quarantine not automatically good cause — Court of Appeal discretion under Order X r.2(8) and s.9(b) Court of Appeal Act.
30 March 2021
Registered title and valid transfer by an administrator prevail over unregistered equitable claims; appeal dismissed with costs.
  • Land law — registered title v. unregistered/equitable interests — protection of persons dealing with registered proprietors (s.58 Lands and Deeds Registry Act) — bona fide purchaser for value without notice — administrators’ power to transfer intestate property by deed of gift/assent — effect of formal deviations from prescribed transfer forms.
30 March 2021
Appellant failed to prove fraud; registered purchasers protected by conclusive title and official search, appeal dismissed.
  • Property — Registered title and official certificate of search — Conclusive statutory effect (Lands and Deeds Registry Act ss.23, 33) — Challenge only on proof of fraud or operative mistake (s.34) — Purchaser from registered proprietor protected; no duty to investigate vendor’s acquisition (s.58).
29 March 2021
Certificate of title and official search are conclusive; appellant failed to prove fraud, appeal dismissed with costs.
  • Lands and Deeds Registry Act — Sections 23, 33, 34, 58–59; certificate of title and official search conclusive; fraud must be specifically pleaded and strictly proved; purchaser from registered proprietor protected; no duty to investigate vendor's acquisition; caveat and registration critical.
29 March 2021
Whether two disputed houses formed part of the deceased's estate and effect of partial payment on vesting and equitable reimbursement.
  • Intestate succession — land title — certificate of title and Lands Register entries conclusive under Lands and Deeds Registry Act — deed of assignment challenged; Property acquired in deceased’s name; deposit versus completion of contract — deposit alone does not vest property in estate; equity and reimbursement where majority of purchase price paid by another party; remedy: title cancellation/reissue and reimbursement with interest.
26 March 2021
Medical proof of defilement does not identify the perpetrator; independent admission and opportunity provided necessary corroboration.
  • Criminal law — Defilement — Corroboration: medical evidence corroborates commission, not identity — Danger of false implication from relative witnesses — Need to warn and exclude such danger — Independent corroboration (admission/confession to third party and opportunity) can supply "something more" to uphold conviction.
26 March 2021
Court upheld aggravated robbery conviction, finding identification by acquaintances reliable despite no identification parade.
  • Criminal law — Aggravated robbery — Identification evidence by acquaintances — Relatives not automatically 'interested' witnesses — Identification parade not mandatory — Alibi must be timely raised — Common purpose and use of firearm.
24 March 2021
Application for leave to appeal and joinder dismissed: proposed appeal lacked public importance and reasonable prospects.
  • Civil procedure — Leave to appeal to Supreme Court — Court of Appeal Act s13(3) — point of law of public importance — reasonable prospects of success — Intestate Succession Act s19(2) — sale of property without High Court consent — joinder — costs follow event.
23 March 2021
Circumstantial evidence—being last with the child, injuries, flight and admission—upheld the appellant's murder conviction.
  • Criminal law — Circumstantial evidence — Last person with victim — Postmortem head injuries — Flight and out‑of‑court admission to a private person — Inference of guilt.
23 March 2021
Leave denied: applicant failed to exhaust statutory complaint procedures and interlocutory referral is challengeable after trial.
  • Judicial review — recusal of trial magistrate — Article 28(2)(a) referral to High Court — Judicial (Code of Conduct) Act — exhaustion of statutory complaints — interlocutory decisions in criminal trials — appeal after trial.
22 March 2021
Whether the 1% arranger fee was of funds "raised" or of cash disbursed and whether adviser fees or architect fees were payable absent development commencement.
  • Contract construction — meaning of "amount raised" versus "disbursed"; arranger success fee split (0.7% land, 0.3% cash); termination and damages — notice and phases of contractual obligations; transaction-advisor/project-manager fees payable when development commences; quantum meruit and course of dealing — no implied obligation without regular, consistent dealings; judgment on admission — inadmissible at judgment stage where evidence contested and interlocutory rulings exist.
17 March 2021
Whether a mortgagee in possession must render a full account of receipts and prove credits, and whether trial accounting was properly determined.
  • Mortgage law — mortgagee in possession — duty to account for rents and profits; burden of proof at accounting lies on mortgagee in possession; clause in mortgage protecting lender's acts does not negate equitable duty to account; admissibility and sufficiency of evidence for credits (improvements, expenses, effects of squatters/mining); appellate correction of factual miscalculation and remit for final accounting.
11 March 2021
Appeal dismissed for want of prosecution under Order 10/7 CAR; costs awarded to the respondent.
  • Civil procedure — Court of Appeal Rules Order 10/7 — dismissal for want of prosecution — failure to file record of appeal and heads of argument — service and hearing in absence — costs.
5 March 2021