Court of Appeal of Zambia - 2022 August

27 judgments
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Results. 27 judgments found.

27 judgments
August 2022
Applicant failed to show good and sufficient grounds for a stay of execution; amendment allowed but stay refused, with costs to respondent.
  • Civil procedure — stay of execution — exceptional remedy requiring good and sufficient grounds — prospects of success and special circumstances; amendment of motion for changed circumstances; execution and possession taken prior to stay application; res judicata as ground of appeal.
31 August 2022
Conviction for possession of forged notes quashed where hearsay and failure to prove accused's knowledge undermined prosecution's case.
  • Criminal law — Possession of forged banknotes — Knowledge an essential ingredient; on-the-spot explanation shifts burden to prosecution — Hearsay evidence inadmissible where key witness not called — Warn-and-caution admissions must be shown voluntary.
26 August 2022
The appellant’s challenge to identification evidence failed; convictions and sentences for murder and grievous harm were upheld.
  • Criminal law — identification evidence — reliability of visual identification at night — suspect witnesses and requirement of corroboration — appellate review of trial judge’s factual findings.
25 August 2022
Appellants’ convictions under State Security Act quashed for lack of proof; one appellant convicted of a lesser Penal Code offence.
  • Criminal law — possession of military/official uniform — State Security Act s6(1)(a) — mens rea requires intention to gain/assist admission to protected place or to prejudice national safety — constructive possession — no case to answer — substitution of conviction with Penal Code s182(4) (unauthorized possession) — sentence adjustment for time served.
25 August 2022
Conviction for defilement overturned where prosecutrix under 14 testified without independent corroboration of the accused's identity.
  • Criminal law — Defilement — Evidence — Requirement of corroboration where prosecutrix under 14 years (s.122 Juveniles Act) — Cautionary rule in sexual offences cannot substitute statutory corroboration — Medical evidence may confirm defilement but not necessarily identity.
25 August 2022
First offender pleading guilty to causing death by dangerous driving should be fined unless an unroadworthy vehicle caused the death.
  • Road Traffic Act — causing death by dangerous driving — sentencing of first offender pleading guilty — aggravating factor: unroadworthy vehicle only where defect caused accident and driver knew — inconsistencies between statement of facts and subsequent reports; procedure per Patel.
24 August 2022
Defective voire dire led to expunging the child’s evidence, quashing conviction and remitting the case for retrial.
  • Criminal law — incest; child of tender years — defective voire dire; requirement to record questions and answers; expungement of juvenile evidence; corroboration; medical evidence; alleged admission; retrial in interests of justice (Court of Appeal Act s16(3)).
24 August 2022
High Court wrongly substituted a more serious unpleaded offence; trial conviction for indecent assault restored and sentence upheld.
  • Criminal law — conviction on uncharged or different offences — limits of section 181(2) and section 186 CPC; substitution of conviction to a more serious offence impermissible; sufficiency of eyewitness evidence and flagrante delicto identification; appellate review of review court substitution.
24 August 2022
Appeal dismissed; appellant's pre-custody admissions admissible; convictions for two murders affirmed and death imposed on each count.
  • Criminal law — Murder — Admissibility of incriminating statements — Judges' Rules and custody — Trial-within-a-trial — Direct admissions vs circumstantial evidence — Forensic pathology (blunt force head trauma) — Investigatory omissions and dereliction of duty — Sentencing multiple offences under s.36(a) Penal Code.
24 August 2022
Employment claims may still be filed on the High Court General List; Industrial Relations Division governed by Industrial Relations Rules.
  • Constitutional status of Industrial Relations Court — Article 133(2) — Industrial Relations Court becomes a High Court division but retains jurisdiction and procedures under the Industrial and Labour Relations Act; Practice and procedure governed by Industrial Relations Rules pending legislation; Per incuriam — failure to consider binding precedent; Employment claims may remain competent on the High Court General List.
24 August 2022
Insanity must be pleaded and proved; medical findings alone insufficient; confession must be tested for voluntariness; conviction upheld.
  • Criminal law — Insanity defence — burden to plead and prove on balance of probabilities; medical report alone not determinative; M'Naghten test; fitness to stand trial; confessions — trial judge's duty to inquire voluntariness; circumstantial evidence sufficiency.
23 August 2022
Murder conviction quashed where absence of postmortem and circumstantial evidence failed to prove the newborn was alive and killed.
  • Criminal law — Murder — Essential ingredient of cause of death — Postmortem not always necessary but required where circumstantial evidence does not exclude reasonable alternatives; Infanticide/stillbirth distinction; Diminished responsibility — burden and relevance of medical evidence.
23 August 2022
Conviction for murder set aside where no postmortem and no evidence the newborn was born alive, making stillbirth reasonably possible.
  • Criminal law — Murder — Essential proof of cause of death — Postmortem evidence — Circumstantial evidence — Need to prove victim was born alive — Absence of postmortem not always fatal but conviction unsafe where reasonable alternative (stillbirth) exists — Diminished responsibility burden on defence.
23 August 2022
Cumulative circumstantial evidence (possession, footprints, conduct) upheld a murder conviction despite absence of post‑mortem and inadmissible spousal testimony.
  • Criminal law — Murder — Circumstantial evidence — Recent possession of victim's property — Matching footwear impressions — Accused leading parties to body — Accomplice/ex‑curia statement — Witness competency (spouse) — Post‑mortem not always necessary.
23 August 2022
A third party’s presence in litigation does not automatically render an arbitration clause inoperative; severance and referral to arbitration permitted.
  • Arbitration law — stay of court proceedings under section 10(1) Arbitration Act — effect of non‑party presence on arbitration clause — severance of disputes — employment contracts and secondment.
19 August 2022
Application to refer bill of costs out of time dismissed; Court found no time limit and refused reliance on the White Book.
  • Costs — Taxation — Order XII Rule 2 Court of Appeal Rules — No express time limit to file bill of costs for taxation — White Book (English Rules) not a substitute for domestic Rules — Application for leave to refer bill out of time dismissed.
19 August 2022
Whether the 10th chief’s selection complied with Bisa customary law and whether the acting chief had authority to convene the selection meeting.
  • Chieftaincy disputes; customary law — Bisa succession and selection procedures; acting/caretaker chief authority; appellate review of factual findings; burden of proof in customary disputes.
16 August 2022
Re-entry under the Lands Act requires lawful service and opportunity to make representations; titles issued from improper re-entry may be cancelled.
  • Lands Act s.13(3) — re-entry and certificate of re-entry — requirement of service and right to make representations; natural justice — notice and fair hearing; proof of service — burden on Commissioner of Lands; Certificates of Title — cancellable where issued following procedural impropriety; admissibility and pleading of administrative correspondence.
16 August 2022
Whether the Minister lawfully suspended the applicant without the Board’s authority, amenable to judicial review.
  • Administrative law — Judicial review — Leave to apply — Locus standi — Public body — Ministerial suspension — Ultra vires — Cabinet Handbook clause 8.11 — Persons with Disabilities Act s.19 — Stay pending review.
12 August 2022
Court grants leave and stay for judicial review, holding Minister likely exceeded statutory and Cabinet Handbook powers in suspending applicant.
  • Judicial review — leave to apply — locus standi/sufficient interest — public vs private law — employment of statutory agency — ultra vires suspension — Cabinet Handbook clause 8.11 — stay pending review.
12 August 2022
Employee confirmed after probation; termination without substantiated reason or hearing was unlawful; damages reduced to three months' pay.
  • Employment law — probation — completion and extension of probationary period — absence of employer communication; Employment Act s36 — requirement for valid, substantiated reason for termination; Natural justice — requirement to lay charges and afford hearing before termination; Wrongful/unfair/unlawful termination — distinction and remedies; Quantum of damages — appellate interference where award is manifestly excessive.
3 August 2022
Appeal dismissed: insufficient explanation for non-attendance and counsel's negligence is not a ground to set aside judgment.
  • Civil procedure — Order 35 HCR — judgment after trial in absence of defendant — sufficiency of explanation for non-attendance; Solicitor negligence — not ordinarily a ground to set aside judgment; Appellate review — limits on disturbing discretionary decisions.
3 August 2022
A writ of fieri facias that ignores prior payments withdrawn is irregular; execution must be stayed pending set‑aside.
  • Execution law — writ of fieri facias — irregular execution where writ fails to reflect payments withdrawn — stay of execution pending set‑aside application — payments into court and effect on enforceable balance — Sheriffs Act liability.
3 August 2022
Sale stayed pending determination of an application to set aside an irregular writ of fieri facias that over‑executed the judgment.
  • Execution law — writ of fieri facias — irregular execution by over‑endorsing amount — stay of execution pending application to set aside — sheriff liability; Rules of the Supreme Court Order 47; Sheriffs Act s.14(2).
3 August 2022
Section 331 requires prior court leave before commencing proceedings on behalf of a company, including in liquidation.
  • Companies law — derivative actions and Foss v Harbottle exceptions — section 331 Companies Act — prior leave required to bring or intervene in proceedings in name of or on behalf of a company (including where company is in liquidation) — claims against delinquent liquidator considered but statutory leave mandatory.
3 August 2022
Employment-related claims must be commenced in the High Court’s Industrial and Labour Relations Division, not the General List.
  • Civil procedure; jurisdiction of High Court — Industrial and Labour Relations Division (HC-IRD) v General List — employment claims; Article 133 Constitution Amendment Act 2016; precedent (PC Cheelo) distinguished.
3 August 2022
Appeal dismissed: judgment on admission valid where signed settlement agreement constituted a clear, unequivocal admission of debt.
  • Civil procedure — Judgment on admission — Admissions may be by pleading or otherwise — Settlement agreement as clear and unequivocal admission — Order 21 Rule 6 and Order 27(White Book) — No requirement to file defence before applying for judgment on admission — Discretion exercised only in plain cases.
2 August 2022