Court of Appeal of Zambia - 2021 May

22 judgments
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Results. 22 judgments found.

22 judgments
May 2021
Buyer entitled to refund where delivered rice failed to correspond with the sample; sellers were co-adventurers and interest and costs awarded.
  • Sale of goods by sample (s.15) — buyer's right to reject — FOB contracts and allocation of costs — co-adventure/joint venture liability — admissibility of unpleaded evidence not objected to — award of interest and costs.
31 May 2021
Whether cumulative circumstantial evidence, recent possession and identifications sufficed to sustain murder and aggravated robbery convictions.
  • Criminal law — Circumstantial evidence; Recent possession of stolen property; Last-seen principle; Suspect witnesses and corroboration; Leading police to recovery — guilty knowledge; Acquittal for insufficient circumstantial proof.
28 May 2021
Whether possession of a tampered, rebranded cow proved stock theft or only receiving stolen property under section 318(1).
  • Criminal law — Stock theft — Burden of proof beyond reasonable doubt — Accused's explanation reasonably possible creates reasonable doubt — Receiving stolen property s318(1) — Improper conviction/sentencing where proven facts differ from charge.
28 May 2021
Postmortem and circumstantial evidence upheld murder conviction; investigative lapse found non‑prejudicial.
  • Criminal law — Murder — Circumstantial evidence — Inference of guilt; Malice aforethought — s.204(b) — knowledge that act likely to cause death; Postmortem evidence — admissibility and reliability despite report errors; Investigative omissions — dereliction of duty and prejudice; Appellate review — deference to trial judge’s credibility findings.
28 May 2021
Whether cumulative circumstantial evidence excluding reasonable alternatives justified conviction of the first appellant, but not the second.
  • Criminal law — Circumstantial evidence — Strands must be considered cumulatively — Cogency required to exclude reasonable inference of innocence; Identification parades; Possession of stolen vehicle and pirating as corroborative circumstance; Insufficient linkage for co-accused where only last-seen evidence exists.
28 May 2021
Teacher’s failure to inquire into a pupil’s age negates the proviso defence to defilement under section 138(1).
  • Criminal law — Defilement under section 138(1) Penal Code — Proviso requiring reasonable belief as to age — Ocular observation not sole test — Teacher-pupil relationship and context of encounter may impose duty to inquire — Recklessness negating reasonable belief.
28 May 2021
Appellate court upheld murder conviction and death sentence, finding eyewitness credible and provocation defence fabricated.
  • Criminal law — murder — credibility assessment of interested witness — corroboration (post-offence admission and flight) — provocation and failed defence as extenuating circumstance — appellate review of factual findings.
28 May 2021
Accidental-discharge defence rejected; deliberate arming, locking and flight supported malice aforethought and upheld murder conviction.
  • Criminal law — Murder — Malice aforethought — Accidental discharge defence — Circumstantial evidence — Firearm handling and knowledge — Loading, locking premises, flight; mens rea inference.
28 May 2021
Malice aforethought proved; provocation and intoxication not established—appeal dismissed and murder conviction with death sentence upheld.
  • Criminal law — Murder — Malice aforethought (s.204(b)) — Provocation and intoxication as failed defences and extenuating circumstances — Witness credibility and suspect witness corroboration — Duty to call witnesses/investigation.
28 May 2021
Credibility findings and common design justified upholding arson convictions despite inconsistencies about who lit the fire.
  • Criminal law — Arson — Identification and credibility of witnesses — Common design/coordinated action — Inconsistencies in who lit the fire immaterial where acts were simultaneous — Appellate deference to trial court credibility findings (Risbey).
28 May 2021
Conviction quashed for lack of independent corroboration of the perpetrator's identity despite medical corroboration of intercourse.
  • Sexual offences — corroboration required of both commission and identity; Juveniles Act s122(b) — corroboration mandatory for witnesses under 14; medical evidence corroborates commission but not identity; opportunity by ordinary cohabitation does not suffice as corroboration.
27 May 2021
Appellant's murder conviction upheld on circumstantial evidence: last seen, accused's coat on body, flight and confession.
  • Criminal law — Murder — Circumstantial evidence — Last seen with deceased — Identification by witnesses with potential interest — Accused's coat found on body — Flight and subsequent statement to police — Accused's explanation rejected.
26 May 2021
Stock theft not proved beyond reasonable doubt; conviction substituted with receiving stolen property and three-year sentence.
  • Criminal law — Burden of proof in theft — Possession of recently stolen property — Reasonable explanation creates reasonable doubt — Lesser alternative conviction: receiving stolen property (s.318(1) Penal Code) — Sentencing must reflect proven facts.
26 May 2021
Convictions based on circumstantial evidence quashed where reasonable alternative explanations existed and evidence was unsatisfactory.
  • Criminal law — circumstantial evidence — must exclude all reasonable inferences other than guilt; Juveniles Act s.122 — voir dire requirements (intelligence and duty to tell truth); adequacy of investigation into defendants' explanations.
26 May 2021
Single-witness identification can be safe if reliable; armed aggravated robbery requires proper charge and direct firearm evidence.
  • Criminal law — Identification evidence: single identifying witness; opportunity to observe and risks of honest mistake. Aggravated robbery — armed aggravated robbery: accused must be charged with armed robbery and there must be direct evidence that a firearm (as defined by the Firearms Act) was used before imposing death sentence. Sentence substitution where conviction for armed robbery set aside
26 May 2021
Court held Bundabunda succession is rotational among three lineages and ordered the next rotation to the Kashimbi family.
  • Customary succession — Bundabunda chieftaincy — rotational succession among three matrilineal families — probative value of family tree and shrine (clay pots) evidence — appellate interference for misapprehension of facts.
22 May 2021
Whether unexplained last‑seen coincidences and recovered personal effects can sustain a murder conviction despite admission voluntariness concerns.
  • Criminal law — Murder — Circumstantial evidence — Last seen and odd coincidences — Admission evidence — Voluntariness enquiry — Ilunga Kabala precedent — Flight and recovery of personal effects.
21 May 2021
Court affirms indecent assault conviction: elements and corroboration satisfied despite non‑material inconsistencies.
  • Criminal law — Indecent assault — Elements: unlawful act and indecency judged by reasonable person test — Consent as defence; Criminal procedure — Corroboration required in sexual offence cases — corroboration of act and identity may be satisfied without witnessing every detail; Evidence — inconsistencies not material do not vitiate conviction.
19 May 2021
Whether a purchaser from a fraudster acquires title and if refusal to adjourn denied the applicant a fair trial.
  • Civil procedure — adjournment — trial judge’s discretion to refuse adjournment; Property law — nemo dat quod non habet — purchaser from fraudster cannot acquire good title; Lands and Deeds Registry Act — certificate of title vitiable for fraud or impropriety; Intestate Succession Act s.19(2) — sale of estate property without court order; Contract formation — offer and acceptance may be inferred from parties’ conduct.
18 May 2021
The appellant's claim failed: advance payment not a condition precedent; respondent entitled to terminate and claim damages.
  • Contract formation — purchase orders and award letter — advance payment not a condition precedent; delivery period counted from purchase order; supplementary purchase order for crane; breach, termination and damages; possessory lien not available.
18 May 2021
50% advance was not a contractual condition precedent; appellant breached by late delivery and could not retain wagons as a lien.
  • Contract law — condition precedent — advance payment — interpretation of purchase orders and award letter; Public Procurement Regulations — advance payment limits; delivery period — commencement date; agreement for hire/transport of crane; breach, termination and damages; possessory lien not available where no debt justifying retention.
18 May 2021
12 May 2021