Court of Appeal of Zambia - 2021

243 judgments
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243 judgments
Citation
Judgment date
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
February 2021
Whether a unilateral variation of a basic employment term fixes the redundancy date and the salary for terminal benefits.
Labour law – unilateral variation of basic conditions of employment – discontinuance of long service gratuity – date of redundancy – computation of terminal benefits on salary applicable at date of variation; review of judgment – fresh evidence – materiality and relevance.
26 February 2021
A summary dismissal without being charged or heard violated natural justice; three months' salary awarded as damages.
Employment law — dismissal v termination — requirement to afford an employee an opportunity to be heard (audi alteram partem) — proof of abscondment — remedies for wrongful and unfair dismissal.
26 February 2021
An expired state lease does not extinguish title; a resettlement allocation cannot override a valid Certificate of Title.
Land law — expiry of state lease; s10(1) Lands Act — renewal not automatic extinguishment; s33/s34 Lands and Deeds Registry Act — conclusiveness of certificate of title; resettlement allocations — lack authority to confer proprietary interest; cancellation of title requires statutory grounds.
26 February 2021
Interlocutory attachment to preserve a disputed vehicle pending trial is proper despite a third‑party purchaser's claim of good faith.
Industrial Relations – Interim attachment of property – Interlocutory relief aimed at preservation not adjudication of title – Third‑party purchaser vs. interlocutory preservation order – Evidence of intent to dispose (auction) – Appellate review of discretionary interlocutory orders – Issues not raised below inadmissible on appeal.
26 February 2021
The applicant’s five‑year failure to file a record of appeal warranted dismissal for want of prosecution.
Civil procedure – Appeal procedure – Record of appeal – Duty of appellant to prepare and file record; inordinate delay and failure to prosecute; High Court (Appeals) (General) Rules (SI No.6 of 1984) – Public interest not a justification for procedural non‑compliance.
25 February 2021
Dispute over farm ownership: company incorporation validated title and subdivision; mesne profits and ex parte possession were set aside.
Companies law – incorporation and membership – expanded MBOT converted into a company acting for shareholders; Land law – Certificate of Title prima facie conclusive, cancellable only for pleaded and proved fraud; Property subdivision – lawful if effected by shareholder resolution and proportionate to contributions; Civil procedure – ex parte writ of possession issued without a possession order is irregular; Mesne profits – not recoverable absent proof a tenancy ended and appellant became trespasser.
25 February 2021
Consent judgments require endorsement by counsel of all parties; a filed notice of discontinuance was effective despite service omission.
Civil procedure – Consent judgment – Must be drawn in terms agreed, expressed "by consent" and endorsed by solicitors for each party; Notice of discontinuance – Effective when filed and notified to Registrar and parties; Change of advocates – Failure to serve former advocate is curable irregularity; Judicial practice – Trial judge should not volunteer rulings without affording parties opportunity to address; Appeal procedure – Objections to orders not before the appeal court are misconceived.
25 February 2021
Whether a trial court may hear forfeiture applications pending appeal and whether an appellate court can order forfeiture.
Forfeiture of property; Forfeiture of Proceeds of Crime Act s.11(4); Narcotic Drugs Act s.34; jurisdiction to order forfeiture; appellate court limits; third‑party claim in forfeiture proceedings.
25 February 2021
Appellant's summary dismissal for unauthorized use of employer fuel upheld; gratuity forfeited; parties bear their own costs.
Employment law - summary dismissal; disciplinary hearing and natural justice; unauthorized use of employer assets; contractual forfeiture of gratuity; costs follow event and judicial discretion.
25 February 2021
Court upheld interlocutory injunction restraining publication, finding the trial judge properly exercised her discretion under defamation injunction principles.
Defamation — interim injunction — Fraser v Evans criteria — irreparable harm and risk of repetition — fair comment defence — interlocutory discretion to decline adjournment — global injunctions (Shamwana v Mwanawasa).
25 February 2021
Continued use and payment for defective goods constitutes acceptance; speculative damages unsupported and appeal dismissed.
Sale of Goods Act 1893 – acceptance and rejection of goods – Section 35; merchantable quality and fitness for purpose; misrepresentation and burden to prove; damages – requirement of proof and quantification; waiver by conduct/acceptance.
25 February 2021
Appeal dismissed: cogent circumstantial evidence and unexplained recent possession of the deceased’s property upheld the murder conviction.
Criminal law – Circumstantial evidence – Recent possession of stolen property – Odd coincidences and opportunity to plant evidence – Reasonable explanation required for possession – Appellate review of factual findings.
24 February 2021
Appellants with ten years' continuous service at separation are entitled to transfer of past pension service; deferral until retirement is unlawful.
Pension law – portability and transfer of accrued past service – deferred/deferred pension abolished – accrued benefits payable on separation where parties' rollout terms so provide; Industrial Relations Division – costs limited to unreasonable delay or vexatious conduct; Civil procedure – cross‑appeal requirements and corporate separateness in assessing comparative practice evidence.
23 February 2021
Whether an extempore ruling suffices and whether the IRD has jurisdiction over employment-related bonuses, medical and flight claims.
Industrial Relations Division – jurisdiction – section 85(9)(c) ILRA – disputes arising from employment contracts – extempore ruling sufficiency – claims for salary/bonuses, medical insurance refund and flight entitlements.
23 February 2021
Omission to seal writ and to endorse addresses is curable; respondent ordered to cure defects and each party to bear own costs.
Court procedure – High Court Rules Order VI r.4 and Order VII r.1(1)(a) – sealing of writ and endorsement of physical, postal and electronic addresses – regulatory vs mandatory rules – curable irregularity; civil procedure – administrative duty of court officers to seal process; equity – limitation on invoking "clean hands" where no equitable relief sought; costs – judicial discretion and when appellate interference warranted.
23 February 2021
Proceeding on original aggravated robbery charges after amendment was a misdirection; prosecution failed to prove aggravated robbery beyond reasonable doubt.
Criminal law – amendment of charge – procedure following amendment (nolle prosequi and re-arrest) – aggravated robbery – burden of proof beyond reasonable doubt – failure to call key witnesses (complainant and assaulted guard) – recent possession – multiplicity of counts for single event – sentencing: requirement to specify term per count and concurrence.
23 February 2021
Commencing claims for declarations and damages by originating notice (instead of writ) deprived the High Court of jurisdiction; judgment void.
Civil procedure — mode of commencement — writ of summons versus originating notice of motion; Landlord and Tenant (Business Premises) Act — declarations and damages require writ and viva voce evidence; jurisdiction — wrong mode of commencement renders proceedings null and void ab initio; injunctions/statutory applications may be brought by originating notice in appropriate cases.
4 February 2021
January 2021
Whether a consultant who failed to secure agreed fiscal incentives had performed the mandate to earn the contractual flat fee.
Contract interpretation – letter of mandate – scope of obligations tied to clause requiring fiscal incentives – payment clause construed as dependent on full performance; extrinsic correspondence and conduct considered but did not vary written mandate; failure to secure statutory incentives defeats entitlement to flat fee.
29 January 2021
Fixed‑term employees who accept shorter renewal contracts and interviews cannot later claim redundancy or breach absent contractual incorporation of manuals.
Employment law – fixed‑term renewable contracts – effluxion of time vs wrongful termination – incorporation of employee/operations manuals into contract – redundancy and entitlement to redundancy/early retirement for fixed‑term non‑pensionable employees – retrospective application of statutory redundancy provisions.
28 January 2021
Whether a verbal engagement amounted to employment; court held appellant was an independent contractor and dismissed the appeal.
Employment law – contract of employment v independent contractor – degree and extent of control – oral contracts and statutory record-keeping – onus of proof and credibility of witnesses.
28 January 2021
The court granted the appellant a seven‑day extension to seek leave to appeal because the judgment copy was provided late.
Application for extension of time – Order XIII Rule 3(1) Court of Appeal Rules – leave to appeal to Supreme Court – Section 13 Court of Appeal Act – late provision of judgment copy – sufficiency of reasons – discretion to extend time.
27 January 2021
Late delivery of the written judgment justified a seven‑day extension to file for leave to appeal to the Supreme Court.
Extension of time – Order XIII Rule 3(1) – sufficiency of reasons – late provision of written judgment – leave to appeal – Section 13 thresholds – premature merit assessment
27 January 2021
Sitting tenancy without an offer and VIP classification do not entitle an occupant to purchase a government house.
Administrative law; government housing — Civil Service Home Ownership Scheme — eligibility requires sitting tenancy plus offer; VIP classification excludes sale; necessity of offer and acceptance; appellate review of factual evaluation.
26 January 2021
Administrator ordered to render account and distribute estate; paternity established on balance of probabilities without DNA test.
Intestate succession – Administrator’s duty to produce inventory and render account (Intestate Succession Act s.19) – Paternity in civil claims proved on balance of probabilities; birth records and witness evidence admissible – DNA testing requires formal application and may not be insisted upon informally – Court bound by record; party’s absence or voluntary departure from court affects right to contest evidence.
22 January 2021
Administrator's sale upheld; fraud unproven; sale (not loan) enforced; damages and costs against purchaser quashed.
Property law – administrator's sale under Intestate Succession Act s.19(2) – bona fide purchaser – fraud allegation standard of proof – contract of sale versus loan – time of the essence and notice to complete – registration of assignments out of time – awards of damages and costs.
20 January 2021
Conviction overturned where circumstantial phone evidence admitted alternative reasonable inferences, entitling appellant to benefit of doubt.
Criminal law — Circumstantial evidence and inferences — Phone found in stolen vehicle — Dock identification reliability — Benefit of doubt where alternative reasonable inferences exist.
19 January 2021
Court dismissed incompetent contempt motion for multiple procedural defects, including failure to obtain leave and improper record filing.
Contempt proceedings — leave to commence required (Order 52 White Book) — affidavit verifying facts — compliance with Supreme Court Rules (records and heads of argument) — amendment/withdrawal and re-filing of defective records — misdescription of parties and locus standi.
18 January 2021
Stay pending determination requires plausible prospects and special grounds; third‑party fraud allegations alone do not suffice.
Civil procedure — Stay of execution pending determination of main cause (Order 47/1 RSC) — Discretionary power to preview prospects of success — Consent judgments — Allegations of fraud/mistake relating to third party do not necessarily vitiate consent orders — Loss of land not adequately atoned by damages.
13 January 2021
Whether registration of a tribunal's refusal of leave for derivative claims bars a parallel derivative suit as res judicata.
Arbitration award – derivative actions – requirement of leave/permission to continue – refusal of leave by tribunal; registration of arbitral award – res judicata and abuse of process; nominal defendant’s right to challenge derivative proceedings; privies and issue estoppel; costs to successful respondents.
13 January 2021
Registered arbitral refusal of leave to pursue derivative claims barred parallel domestic derivative litigation as abuse and res judicata.
Arbitration – refusal of leave to pursue derivative claims – registration of arbitral award as domestic judgment – res judicata and multiplicity of actions; Derivative actions – role of nominal defendant – standing and procedural challenges; Privity – corporate control and application of issue estoppel; Costs – entitlement of all successful respondents where action dismissed.
13 January 2021
Whether a limitation defence can be enforced where a consent judgment reserved the issue despite no formal plea.
Limitation Act 1939 s.2(1)(a) – six-year bar for actions on simple contract; Consent judgment – binds parties and may reserve preliminary issues for determination; Amendment of pleadings – Order 20 r.3 RSC; Pleading limitation – Order 18 r.8(1) RSC; Limitation defence may be raised by plea, preliminary issue, or strike-out as abuse/frivolous/vexatious.
12 January 2021
Unilateral reduction of severance multipliers without express employee consent invalidated the changes; appeal dismissed.
Employment law – Variation of terms – Unilateral reduction of severance/ex‑gratia multipliers – Requirement of express consent – Implied/acquiesced consent caution – Inclusion of allowances in terminal benefit calculations – Circulars cannot downgrade fundamental conditions without employee consent.
12 January 2021