Court of Appeal of Zambia - 2022

229 judgments
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229 judgments
Citation
Judgment date
December 2022
Applicant’s application for leave to appeal out of time and stay dismissed for delay, insufficent reasons, and lack of merit.
Civil procedure — application for leave to appeal out of time and stay of execution — discretion under Order XIII r.3(1) — requirement of sufficient reasons for extension — non‑compliance with time limits — application dismissed.
30 December 2022
Stay of execution dismissed for failure to show prior application to the lower court under required procedural rule.
Civil procedure – Stay of execution – Requirement to first apply to the High Court – Order XIII Rule 12 – Failure to prove prior stay application – Dismissal with costs.
30 December 2022
A renewed stay application is misconceived where the lower court has already granted a conditional stay; challenge conditions by appeal.
Civil procedure — Stay of execution pending appeal — discretionary remedy; conditional stay; security for costs as condition; interlocutory applications to single judge; challenge to conditions by appeal.
30 December 2022
An administrator cannot mortgage estate property without authority; a lender is bound by constructive notice from occupation.
Intestate succession — powers of administrator — equitable mortgage; constructive notice and occupation — lender's duty of due diligence when title in deceased's name; administrator prohibited from deriving pecuniary benefit from estate.
29 December 2022
Issuing a writ of fieri facias before court-ordered assessment of amounts due is irregular and may be set aside.
Civil procedure — Execution — Writ of fieri facias issued prematurely before assessment — Assessment of amounts due by Registrar/accountant required — Risk of unjust enrichment — Execution set aside for irregularity.
29 December 2022
Application for security for costs and stay dismissed where appellant is resident, traceable and has already paid into court.
Civil procedure – Security for costs – Order X Rule 8(1) Court of Appeal Rules – security for past and prospective costs – discretion to order security – domicile and traceability of appellant – risk of stifling litigation – taxation of costs – guidance from Isaac Lungu v Mbewe Kalikeka.
29 December 2022
An administrator cannot mortgage estate property; lenders must conduct due diligence and are bound by constructive notice.
Intestate Succession Act — administrator’s duties and limits — prohibition on deriving pecuniary benefit; equitable mortgage; constructive notice from occupation; lender’s duty of due diligence.
29 December 2022
Application for leave to appeal out of time and for stay dismissed for inordinate delay and insufficient reasons.
Civil appeals — leave to appeal — extension of time — Order XIII Rule 3(1) — inordinate delay and insufficient reasons — prejudice and finality — stay of proceedings refused.
27 December 2022
Entry of judgment on admission appropriate where defence and correspondence contain clear, unequivocal admission of debt.
:[
23 December 2022
An application to stay execution pending appeal is irregular and dismissed where no prior High Court stay application was made.
Civil procedure — Stay of execution — Appeal does not stay execution unless court orders — Application for stay must first be made to the High Court (Order XIII r.12) — Failure to comply renders application irregular.
23 December 2022
A ruling delivered after the ILRA one‑year limit is null, rendering any subsequent appeal incompetent.
Industrial and Labour Relations Act s85 – mandatory one‑year disposal requirement – jurisdiction tied to time; decision delivered outside statutory period is null and void; jurisdictional issues may be raised at any stage; arbitration clause/enforceability (raised but not decided due to time bar).
23 December 2022
A statutory one-year disposal requirement under s85 ILRA is mandatory; decisions made after that time are void and appeals are incompetent.
Industrial & Labour Relations Act s85 — statutory one-year disposal period — jurisdiction tied to time; decisions delivered outside prescribed period null and void; jurisdictional points may be raised at any stage; consequences for appeals where lower court lacked jurisdiction.
23 December 2022
22 December 2022
Appeal succeeded where trial court relied on unpleaded duty-to-explain findings; signed surety agreement bound the 2nd respondent.
Civil procedure – pleadings and evidence – court must not decide on unpleaded matters; suretyship – signature binds surety; estoppel against denying signed obligations.
21 December 2022
Appeal dismissed for want of prosecution where the Record of Appeal was not timely filed and no timely extension was sought.
Civil procedure — Court of Appeal Rules (Order 10 Rule 7) — Dismissal for want of prosecution — Failure to file Record of Appeal within time — Duty to seek extension promptly — Precedent: appellants who 'sit back' risk dismissal (Nahar Investment).
20 December 2022
Termination without substantiated reasons breaches section 36; court awards each appellant twelve months' basic salary.
Employment law — Section 36 Employment Act — requirement to give valid, substantiated reasons for termination; verbal notice insufficient; localization clause not a substitute for substantiated reasons; damages for unlawful termination — departure from normal measure; award of twelve months' salary.
20 December 2022
Dying declaration admitted; murder conviction upheld; arson conviction quashed for lack of wilful intent.
Criminal law – admissibility of dying declaration – maker’s settled hopeless expectation of death – circumstantial evidence – assessment of accused’s conduct – arson under s.328 Penal Code requires wilful intent to set property on fire; reckless/spread-of-fire not covered – mandatory life sentence for arson only where fire to property causes death.
16 December 2022
Whether provocation or failed provocation can mitigate a murder sentence when the appellant denied causing the death.
Criminal law – Murder – Provocation defence – Elements: provocative act, loss of self-control, proportionate retaliation – Failed provocation as extenuation – Raising provocation on appeal when accused denies causing death – Circumstantial evidence sufficiency.
16 December 2022
Whether a ministerial renewal can validate a fixed‑term appointment absent the Board’s statutory authority, and related entitlements.
Administrative law; statutory appointment powers — Board’s exclusive power to appoint/renew Director‑General under Water Resources Management Act; ultra vires acts by Minister; Employment Act s.28C and fixed‑term contract renewal; effluxion of time; estoppel cannot validate breach of statutory appointment requirements; entitlement to reimbursement where title not passed.
16 December 2022
Murder conviction and death sentence upheld; grievous-harm conviction quashed for lack of intent.
Criminal law — Murder by firearm — Circumstantial evidence and expert ballistic/pathology evidence; Self-defence and accidental discharge; Mens rea for acts intended to cause grievous harm — requirement of specific intent; Trial procedure — court visit to scene; Sentencing — death penalty and extenuating circumstances.
16 December 2022
Appeal dismissed; registered title upheld absent pleaded or proved fraud or evidence estate exceeded Local Court jurisdiction.
Succession and probate – Local Court jurisdiction under Intestate Succession Act s.43(2) – validity of deed of assent and registration – Certificate of Title conclusive absent fraud (Lands and Deeds Registry Act) – limits of judicial notice regarding property values.
16 December 2022
Whether a shareholders' resolution can validly transfer individual borrowers' loan liability to the company without the lender's prior consent.
'Personal Liability Transfer Agreement' – effectiveness of shareholders' resolution in shifting loan liability to company; Doctrine of privity of contract and Clause 13.
15 December 2022
Whether a written sale with a buy-back option constituted an equitable mortgage and whether the Money Lenders’ Act applied.
Property law – contract of sale with buy-back option – distinction between sale and equitable mortgage; Evidence – primacy of clear written instrument; Statutory law – Money Lenders’ Act inapplicable to sales; Contract law – freedom of contract; LAZ Conditions of Sale – temporal applicability.
15 December 2022
A defective voir dire omitting a child's understanding of the duty to tell the truth invalidated child evidence, prompting quashing of conviction and retrial.
Juveniles Act s122 — voir dire; requirement that child witness understands duty to tell the truth; defective voir dire renders child evidence void; child evidence and corroboration in sexual offences; retrial ordered.
15 December 2022
Appellant failed to prove consultant underperformed; trial court's factual findings and reasoning upheld, appeal dismissed with costs.
Contract law – consultancy services – performance and entitlement to fees – breach and substantial failure to perform – counterclaim for losses due to alleged underperformance – appellate review of factual findings (perversity standard) – sufficiency of judicial reasoning (Habasonda).
15 December 2022
Defective voir dire expunged child evidence; no independent corroboration existed, so conviction quashed and appellant acquitted.
Criminal law – defilement – juvenile voir dire must record questions and answers – defective voir dire leads to expungement of child evidence – necessity of independent corroboration of identity – hearsay cannot substitute for corroboration – retrial not ordered where insufficient admissible evidence.
15 December 2022
A Commercial Division litigant cannot invoke Article 118(2)(e) to avoid consequences of post-default non-compliance with court directions.
Civil procedure — Commercial Division — Order 53 and Orders for Directions — extension of time — post-default applications — Article 118(2)(e) Constitution — strict compliance — consequences for disobedience of court directions.
15 December 2022
Repeated loans to one borrower do not alone make a lender a "money-lender" requiring a licence under the Money Lenders Act.
Money Lenders Act — definition of "money-lender" — requirement to be in business, advertise or hold out — repeated loans to single borrower insufficient to constitute money-lending business — licence under section 3 not required absent carrying on business or holding out.
15 December 2022
Appellate court upheld trial judge’s credibility findings that the Appellant’s forklift caused the collision; appeal dismissed with costs.
Tort — Negligence; motor vehicle collision allegedly caused by a protruding forklift fork — Evaluation of witness credibility; appellate deference to trial findings of fact — Relevance of paint marks and presence of third vehicle — Admissibility/reliance on police report.
15 December 2022
Appellate court reduced an excessive 35‑year defilement sentence where a trial court factual misstatement influenced severity.
Criminal law – Defilement – Sentencing – Appellate interference – Jutronich criteria – Borderline victim age (15 years 8 months) – Trial court factual misstatement – Aggravating factors: abduction, confinement, ill‑treatment – Sentence reduced from 35 to 20 years.
15 December 2022
Repeated loans to a single borrower do not, alone, make a lender a licensed "money-lender" under the Act.
Money Lenders Act – definition of "money-lender" – requirement to be carrying on business, advertise or hold out as lender – multiple loans to single borrower insufficient to constitute business of money-lending – licence requirement under section 3.
15 December 2022
Whether withdrawal of an appeal from the procuring entity vitiates an appeal pending before the procurement Authority and arbitration jurisdiction.
Public procurement appeals — interpretation of section 70 of the repealed Public Procurement Act and Regulations 170–174 — arbitration agreement and jurisdiction to stay proceedings — effect of withdrawing an appeal from the procuring entity on an appeal lodged with the Procurement Authority.
15 December 2022
Unsigned employment agreements render employees orally employed and entitled to redundancy pay and payroll retainment until paid.
Employment law – redundancy – oral versus written contracts – Section 26(b)(3) Employment Act – retention on payroll until redundancy paid – entitlement to minimum wage differences – interest on unpaid employment benefits.
15 December 2022
An appellate court will not disturb a trial court's personal injury award absent misdirection, misapprehension of facts, or manifest unreasonableness.
Civil damages — assessment of damages for personal injury — appellate interference only if wrong principle, misapprehension of facts, or manifestly unreasonable award — aggravating factors and inflation may justify higher awards.
14 December 2022
Assessment must quantify actual loss (market value) — mortgage proceeds are not an automatic measure of compensatory damages.
Property torts – wrongful occupation/encroachment – measure of damages for loss of use of land – market value versus mortgage proceeds; assessment procedure – assessor must independently quantify actual loss; special damages require pleading and proof; unjust enrichment principle in damages assessment.
14 December 2022
Appeal upheld where court proceeded without proof of service of the adjourned hearing, causing procedural injustice and remittal.
Natural justice — service of process — adjournment and notice of hearing — proof of service required before proceeding in absence; res judicata and abuse of process; consent judgments and multiplicity of actions; remittal for fresh hearing.
14 December 2022
Director improperly joined where claim arose against company and no pleading sought to lift corporate veil.
Civil procedure – misjoinder – Order 14/5(2) HCR; Joinder and necessary parties – Order 15/6 RSC; Corporate law – separate legal personality and limited liability; Piercing the corporate veil – required pleadings or application before imposing personal liability on a director; Companies Act s.85(5) – inappropriate to determine substantive personal liability at misjoinder stage.
14 December 2022
Appeal allowed: director improperly joined where pleadings did not plead piercing the company’s corporate veil.
Civil procedure – misjoinder and striking out – Order 14/5(2) HCR and Order 15/6 RSC; Company law – separate legal personality and lifting the corporate veil; Companies Act s85(5) – personal liability of directors; pleadings – requirement to plead basis for piercing corporate veil before imposing personal liability.
14 December 2022
Appellate court found insufficient evidence of encumbrance, upheld conditional refund clause, ordered property advertised for resale.
Contract law – sale of land; misrepresentation – entitlement to rescission/refund; Statute of Frauds – enforceability of signed memorandum; appellate interference with unsupported factual findings; obligation to effect conditional refund by resale.
12 December 2022
Court set aside single‑judge dismissal, granted applicant extension to file appeal and heads, and annulled the costs order.
Civil procedure — application to reverse single‑judge ruling; extension of time to file Record of Appeal and Heads; dismissal for want of prosecution; procedural priority of competing applications; discretion as to costs.
12 December 2022
Whether communications accompanying a writ satisfied the mandatory letter-of-demand requirement under Order VI Rule 1(1)(d).
Civil procedure — High Court Rules Order VI Rule 1(1)(d) — Letter of demand — Content of demand letter — Constructive dismissal — Curability of procedural non-compliance.
12 December 2022
Evidence from detained co-suspect witnesses requires independent corroboration before sustaining a conviction.
Criminal law – witness with interest to serve – detained co-suspect witnesses require corroboration; Evidence – inferences from absence/flight and proximity insufficient without independent corroboration; Standard of proof – beyond reasonable doubt.
9 December 2022
Circumstantial evidence showed the appellant inflicted stab wounds, but proximate causation of death was not proven, conviction reduced.
Criminal law — Circumstantial evidence — sufficiency of inference; Causation — proximate cause and chain of causation in homicide where immediate cause was pneumonia; Expert evidence — weight and limits of pathologist’s opinion; Investigations — failure to lift fingerprints and produce deceased’s statement weighed in context; Section 181 CrPC — substitution to lesser offence.
9 December 2022
Circumstantial evidence may prove stabbing, but murder requires proof that the stabbing proximately caused the death.
Criminal law — Circumstantial evidence — Proof beyond reasonable doubt — Proximate cause of death — Expert medical opinion; failure to lift fingerprints and absence of deceased’s written statement assessed against totality of evidence.
9 December 2022
Witnesses detained as potential co-suspects require corroboration; uncorroborated testimony led to quashing of convictions.
Criminal law — Murder; witnesses detained as co-suspects — witnesses with possible interest to serve — requirement of corroboration; circumstantial corroboration — flight and proximity insufficient alone; appellate review of credibility findings.
9 December 2022
Self-defence rejected; despite no recovered weapon, court upheld murder conviction and mandatory death sentence.
Criminal law – murder – malice aforethought – self-defence and provocation – absence of recovered weapon – inferential proof – mandatory death sentence – evaluation of factual findings.
9 December 2022
Opportunity evidence (shared bed) can supply the 'something more' required to corroborate identity in a defilement conviction.
Criminal law – Defilement – Corroboration of identity – Opportunity evidence as corroboration/'something more' – Voir dire in relation to child witnesses aged 14 – Trial‑within‑a‑trial and alleged confession – Paternity/DNA not determinative in defilement.
9 December 2022
Whether self-defence or provocation excused the killing, and whether extenuating circumstances warrant commuting the death sentence.
Criminal law – Murder – Defences of self-defence and provocation – Credibility of witnesses and corroboration of suspect witness – Missing video evidence presumption displaced by police evidence – Extenuating circumstances justifying commutation of death sentence.
8 December 2022
The appellant's challenge to a murder conviction based on self-defence and absence of a weapon was dismissed; conviction and death sentence upheld.
Criminal law – Murder – Malice aforethought (s.204 Penal Code) – Self-defence and provocation – Post-mortem stab wound – Absence of recovered weapon – Manslaughter vs murder with extenuating circumstances – Appellate evaluation of circumstantial inferences.
8 December 2022
A defective voire dire does not defeat a sexual-offence conviction where independent corroborative evidence proves guilt.
Criminal law — Indecent assault; voir dire for child witnesses (Section 122 Juveniles Act) — defective voire dire and exclusion of child evidence — corroboration requirement in sexual offences — eyewitness evidence and 'opportunity' as corroboration — admissions to non-police persons — relatives/friends not automatically suspect witnesses.
8 December 2022