Court of Appeal of Zambia - 2022

229 judgments
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229 judgments
Citation
Judgment date
September 2022
An appeal does not automatically stay execution; applicants failed to show compelling reasons to warrant a stay.
Civil procedure — Stay of execution — Discretionary remedy — Appeal does not automatically operate as a stay — Good, special or compelling reasons required — Disclosure of assets/income and proof of inability to pay — Order 59 Rule 13.
5 September 2022
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
July 2022
Whether an unsigned, condition-dependent share sale permits specific performance, interim payments, or compelled account orders.
Company law – Share purchase agreement – enforceability where price contingent on due diligence – specific performance – part performance – director remuneration – company accounts – right to inspect financial records.
28 July 2022
Whether exchange rate at enforcement applies and whether a Registrar may vary a judge's interest order on assessment.
Civil procedure – assessment of damages; foreign‑currency judgment conversion — applicable rate at enforcement; Registrar’s limited powers; interest — compounding interest and unjust enrichment; set‑off; Judgments Act.
28 July 2022
Documents like registration extracts and bills of lading need not be authenticated under the Act; claimant established pre‑offence interest, so forfeiture set aside.
Forfeiture of proceeds of crime – third‑party claims under ss.12(2) and 31(2) – proof of interest and timing of acquisition – Authentication of Documents Act – what constitutes a document requiring authentication – burden of proof on claimant.
28 July 2022
Conviction for defilement set aside where defective voire dire rendered child’s sworn evidence inadmissible and uncorroborated.
Juveniles Act s122 – voir dire requirements; child witnesses; duty to speak the truth; corroboration in sexual offences; unsafe conviction and no retrial.
25 July 2022
Recent possession of multiple stolen items shortly after an attack supported only the inference of guilt; convictions upheld.
Criminal law – Circumstantial evidence – Recent possession of stolen property – Whether only inference of guilt reasonably open – Duty to consider lesser inferences – Caution as to witnesses with possible interest.
25 July 2022
Where death follows a spontaneous mob assault and the fatal blow cannot be attributed, conviction reduced to manslaughter.
Criminal law – Identification by single witness – recognition of known person; Mob justice – joint participation and attribution of fatal blow; Murder v Manslaughter – where multiple assailants cause death and fatal blow cannot be attributed; Corroboration – role of video and clothing evidence.
25 July 2022
Trial court wrongly excluded competent spouse evidence; retrial ordered due to procedural errors and potential prejudice.
Criminal law – admissibility of spouse testimony – Section 151(1)(c) Criminal Procedure Code – spouse competent where offence affects spouse or children; child witness voir dire – capacity and appreciation of duty to tell truth; appellate relief – retrial warranted where trial court excludes competent evidence and omits material credibility findings.
25 July 2022
Identification by prior acquaintances upheld, but post‑departure firearm discharge did not support armed aggravated robbery, death sentences quashed.
Criminal law – Identification/recognition evidence – prior acquaintance, opportunity and description – single witness reliability; Armed aggravated robbery – use of firearm ‘at or immediately before or immediately after’ stealing – discharge after leaving not sufficient to support armed robbery conviction.
25 July 2022
Conviction overturned where child witness’ evidence lacked required corroboration and medical report was inconclusive.
Criminal law — Defilement — Evidence of child under 14 requires corroboration (Juveniles Act s122); insufficient corroboration of identity; inconclusive medical report requiring oral evidence; alibi assessment and police investigation deficiencies.
25 July 2022
Payment of the claimed sum into the respondent’s account amounted to clear admission, justifying judgment on admission and interest under the Judgments Act.
Civil procedure – judgment on admission – admission by conduct (payment) – requirement that admission be clear and unequivocal – discretion to enter judgment on admission – interest under Judgments Act.
19 July 2022
Dedicated transformer capacity vested in the 2nd respondent; appellants had no supply contract and failed to prove breach or damages.
Electricity supply – dedicated transformer capacity – privity of contract – lawful disconnection for breach of payment condition – supplier’s duty to consumer where no supply agreement exists – costs follow the event.
19 July 2022
Single-judge grants leave to appeal and stays execution where draft defence raises triable issues.
Court of Appeal — leave to appeal under Order X R4(5) — setting aside default judgment — test for leave: real/high prospect of success — stay of execution pending appeal.
19 July 2022
June 2022
Writ served outside jurisdiction is irregular but curable; arbitration referral requires a formal Section 10 application.
Civil procedure – Appearance – Statutory Instrument No.58/2020 amended Order 11; conditional appearance abolished; memorandum of appearance and defence required Service out of jurisdiction – Issuance and service of writ outside Zambia without leave is irregular but curable where no prejudice or default judgment Arbitration – Stay and referral under Section 10(1) Arbitration Act require a proper motion/summons; skeleton arguments do not substitute formal application Third party/Remoteness – Applicability of arbitral clause to third parties requires proper pleading and was not before the court Costs – Party serving process irregularly condemned to costs for the improper strike-out application
30 June 2022
27 June 2022
An inordinate, unexplained delay by the applicant did not justify extending time to file the record of appeal despite COVID‑19 reasons.
Court of Appeal Rules — extension of time (Order XIII Rule 3) — sufficiency of reasons — inordinate delay — COVID‑19 registry delays do not automatically justify extension — duty to prosecute appeals promptly — prejudice and finality of litigation.
23 June 2022
The appellant proved special damages from the respondent’s razing of premises; appeal allowed and damages awarded.
Evidence - burden of proof - special damages; Lease termination - notice periods and breach; Appellate review of factual findings; Valuation - fair market value assessment; Unpleaded issues considered where not objected to.
23 June 2022
Leave to appeal granted where trial judge assumed collusion and effectively pierced corporate veil without proper findings.
Leave to appeal – test of realistic prospects of success; Interpleader proceedings – Order XLII Rule 2(b) High Court Rules – burden to show non-collusion; Enforcement of foreign judgment – execution and seizure of goods; Corporate personality – piercing the corporate veil and single economic unit doctrine; Time limits – notice of claim within five days.
23 June 2022
Whether the appellant was a bona fide purchaser for value without notice of a sitting tenant's equitable interest.
Property law — bona fide purchaser for value without notice; constructive notice and caveats; sitting tenant equitable interest; due diligence via Lands and Deeds Registry searches; review of judgment under Order 39.
17 June 2022
Leave to appeal refused where repeated discovery applications were res judicata and constituted abuse of process.
Civil procedure — discovery — further and better list of documents — Order 24 RSC (rule 7) — res judicata applied to interlocutory applications — abuse of court process — leave to appeal to Supreme Court under Section 13 Court of Appeal Act.
16 June 2022
Administrator's persistent mismanagement, unauthorized sales and failure to account justified revocation of letters and replacement administrator appointment.
Intestate succession — administrator's duties and powers — failure to render accounts and unauthorized sales as grounds for revocation of letters of administration; caveat as protective measure; equitable adjustment of distribution for misappropriated proceeds.
16 June 2022
A conviction grounded on nighttime recognition was quashed for failure to exclude honest but mistaken identification.
Criminal law – identification evidence – recognition by acquaintances – night-time observation – need to exclude honest but mistaken identification – conviction unsafe where identification evidence is unsatisfactory.
15 June 2022
Excluding a defence recording without testing its authenticity breached the appellants' right to a fair trial; convictions set aside and retrial ordered.
Evidence — admissibility of electronic recordings — court must allow evidence on circumstances of recording and may listen to recordings before excluding; fair trial — exclusion of defence evidence may render trial unfair; remedy — retrial ordered where prejudice shown.
15 June 2022