Court of Appeal of Zambia - 2023

327 judgments
  • Filters
  • Judges
  • Topics
  • Alphabet
Sort by:
327 judgments
Citation
Judgment date
December 2023
Appellant acquitted where circumstantial evidence failed due to unresolved postmortem and identification discrepancies.
Criminal law — Circumstantial evidence — Requirement that inculpatory facts be incompatible with innocence and point to no other reasonable hypothesis — Identification and postmortem discrepancies (sex of examined body) — Trial judge’s duty when expert findings conflict with other evidence — Conviction set aside for insufficient circumstantial proof.
29 December 2023
A non-party who is materially affected may obtain a stay of a charging order pending appeal if the appeal has reasonable prospects.
Civil procedure — Stay of execution — Appellant/non-party/intervenor may, in exceptional circumstances, seek stay of a charging order pending appeal — court may preview prospects of success — registration of charging order does not automatically bar stay.
29 December 2023
Appellants' murder convictions and death sentences upheld where relative eyewitness and post-mortem corroborated common-intention lethal assault.
Criminal law – Evidence of relative-witness – caution but capable of acceptance if no motive to fabricate; Criminal law – murder – common intention (s.22) and joint liability for fatal assault; Criminal law – provocation/mob justice – not established where group assault shows intent to cause grievous harm; Evidence – post-mortem corroboration of fatal traumatic injuries.
27 December 2023
Whether evidence supported convictions for theft by public servant and money‑laundering, and whether sentencing, forfeiture and costs orders were lawful.
Criminal law — Theft by public servant — proof requires evidence of original theft and diversion — documentary and circumstantial corroboration; Money‑laundering — transactions in proceeds of crime — consolidation of repetitive counts into a single laundering conviction; Judicial conduct — mere prior employment with prosecution authority does not mandate recusal; Forfeiture — assets proved to derive from proceeds of crime subject to forfeiture; Sentencing — concurrent vs consecutive sentences and appellate adjustment; Statutory judgment — must account for value of forfeited assets before entry.
22 December 2023
Appeal dismissed: offer created enforceable land rights; Commissioner’s cancellation and vitiation of title upheld; counterclaim untenable.
Land law – offer by Commissioner of Lands – offer and acceptance can create enforceable proprietary rights pre‑registration; Cancellation of lot by Commissioner – effect on certificates of title; Fraud or mistake vitiating title; Admissibility and weight of private surveyor plans; Separate legal personality of company and shareholder; Absolute privilege of pleadings – cannot ground civil claims; Appellate procedure – expunging non‑compliant grounds of appeal.
22 December 2023
Appeal dismissed for want of prosecution due to inordinate delay and prejudice to the respondent.
Civil procedure — Dismissal for want of prosecution — Order X r7 Court of Appeal Rules — Failure to file Record of Appeal and Heads of Argument despite extensions — Inordinate and inexcusable delay — Prejudice to respondent — Exercise of court's discretion to dismiss.
15 December 2023
Application for leave to Supreme Court denied: no public importance, no reasonable prospects, regulatory breach deemed curable.
Civil procedure – leave to appeal to Supreme Court – public importance and prospects of success – distinction between curable breach of regulatory rule and fatal breach of mandatory rule – jurisdiction to hear extension of time after dismissal for incompetence.
14 December 2023
Whether a whistleblower may obtain judicial review and interim protection despite delay and employment-law overlap.
- Public Interest Disclosure (Whistleblowers Act) – Sections 10 and 49(1) – protection from occupational detriment and right to relief - Judicial review – leave to apply – extension of time – Order 53 rules - Competence of renewal – ex parte prior refusal does not bar renewal under proviso to Order 53(3)(4)(b) - Public law vs private law – employment-related reprisals arising from protected disclosures may be subject to judicial review - Interim relief – stay of transfer and disciplinary proceedings; payment of withheld salary; provision of safe accommodation
13 December 2023
Justification and fair-comment defences upheld where unchallenged internal investigation supported respondent's statements.
Defamation — justification and fair comment; admissibility and weight of unchallenged documentary evidence; administrative investigations as basis for publication; absence of malice; causation of business loss.
13 December 2023
Registrar correctly computed three months' post-judgment interest due to the appellant; appeal dismissed.
Interest on judgment sums — computation of period and rate — Registrar’s assessment upheld — appellate court will not overturn factual findings absent perversity (Marcus Achiume).
10 December 2023
Applicant failed to show prospects of success or irreparable harm; stay of single Judge's discharge of injunction dismissed.
Civil procedure – interlocutory relief – stay of execution of single Judge’s decision – inherent appellate jurisdiction to preserve status quo pending motion under section 9(b) – whether there is something to stay – prospects of success and irreparable harm required.
10 December 2023
Registrar's dismissal for assessment was quashed for relying on the wrong judgment; matter remitted for hearing.
Civil procedure — Assessment of damages — Registrar's dismissal based on wrong prior judgment — Misdirection — Default judgment awarding punitive/exemplary damages — Matter remitted for Registrar's hearing.
8 December 2023
Where statute does not specify mode, recovery of rent arrears and notice pay may be commenced by writ of summons.
Landlord and Tenant (Business Premises) Act — Rule 3 — mode of commencement — originating notice of motion applies only to matters specified in the Act; recovery of rent arrears and notice pay not covered — where statute silent, Order 6 High Court Rules (writ of summons) applies — appellate correction of erroneous dismissal.
8 December 2023
Whether the Administrator-General is liable for refunds from a void sale when the purchaser failed to exercise due diligence.
Succession and land law — validity of sale by revoked administrator — bona fide purchaser and constructive notice — duty to obtain court authority under s.19(2) Intestate Succession Act — Administrator-General liability and devastavit — costs follow the event.
8 December 2023
Full court dismissed motion because the applicant brought it as an appeal rather than the required renewal, so merits were not considered.
Civil procedure — Renewal of applications from single Judge to full court — Section 9(b) Court of Appeal Act and Order 10 r.2(8) CARs — Procedural competence — Application dismissed for being presented as an appeal rather than a renewal — Merits not considered.
8 December 2023
Expelled members who abandon challenge to their expulsion lack locus standi to contest association elections.
Civil procedure — Locus standi — Expelled association members — Abandonment of challenge to expulsion — Standing to challenge internal elections; Association constitution — Article 5.9 (d),(e),(f),(g) — Procedure for removal, interim administration and candidate eligibility; Appeal — Preclusion from merits where standing absent.
8 December 2023
Court of Appeal lacks jurisdiction; appeals from the Competition and Consumer Protection Tribunal lie to the High Court.
Civil procedure – Appealability – Jurisdiction – Whether Court of Appeal may hear appeals from Competition and Consumer Protection Tribunal – Section 75 Competition and Consumer Protection Act – Appeals to High Court.
8 December 2023
Subordinate Court lacked jurisdiction over titled land; owner's title upheld and occupier's damages set aside.
Jurisdiction – Subordinate Court power over titled land; Certificate of title conclusive evidentiary weight; Possession actions — correct defendant is occupant; Occupier without title not entitled to damages; Procedural defects and nullity for want of jurisdiction.
4 December 2023
November 2023
Delay and failure to prosecute barred setting aside judgment; stolen goods doctrine made appellant liable for conversion.
Civil procedure – setting aside judgment – inordinate delay; Counsel’s withdrawal – no documentary proof required of attempts to obtain instructions; Conversion/stolen goods – buyer from thief acquires no title; Market overt exception; Abuse of process and sleeping on rights.
30 November 2023
Interim injunction discharged where applicant failed to show a prima facie case or irreparable harm against non‑signatory appellant.
Injunctions — American Cynamid factors — requirement of a serious question to be tried; adequacy of damages; balance of convenience; clean hands. Party‑status to contractual documents — necessity of establishing prima facie case against specific defendant. Exploration licence v. mining activities — material non‑disclosure may affect equitable relief but did not save respondent here.
24 November 2023
Appeal dismissed for lack of jurisdiction; appellant should have renewed the injunction application before a single judge.
Civil procedure – interlocutory injunction – appealability – renewal application to a single judge of the Court of Appeal required after refusal; Jurisdiction – appellate procedure – improper route defeats appeal; Property law – interest in land – adequacy of damages argued but not determined.
24 November 2023
An on‑demand guarantee gives rise to an independent cause of action; suing guarantors did not constitute abuse of process.
Civil procedure – Abuse of court process – Multiplicity of actions – Piecemeal litigation – Risk of conflicting decisions; Contract/Guarantees – Unconditional (on‑demand) guarantee – Liability arises on demand; Counterclaims and consolidation – when appropriate.
24 November 2023
Charging 8% monthly and compounding interest violated the Money Lenders Act; foreclosure inappropriate where sale governs remedy.
Money Lenders Act – interest cap (48% p.a.) – excessive interest (96% p.a.) unlawful; prohibition of compound interest; effect of illegality on related contract of sale; equitable mortgage – foreclosure v. specific performance; validity of restructured loan lacking proof of disbursement; enforceability of written sale and assignment.
24 November 2023
Non-registration of letters of administration renders them void but the defect is curable by court discretion; case remitted for trial.
Lands and Deeds Registry Act – registration of letters of administration – s.5(3) and s.6 – effect of non-registration; Curable procedural defect – court’s discretion to extend time under s.6 and Order XVI Rule 1; Locus standi of administrators where interest in land persists.
24 November 2023
A trial de novo does not bar amendment of pleadings; amendments allowed unless they cause irremediable prejudice, appeal remitted.
Civil procedure – trial de novo – meaning and scope; amendment of pleadings – Order 18 R.1 High Court Rules; amendments allowed unless prejudicial; remittal for reconsideration.
24 November 2023
Appeal substituted manslaughter conviction and ten‑year sentence for an original murder conviction and death sentence.
Criminal law — Provocation and self‑defence — failed defences and extenuation — proportionality of retaliation — murder v manslaughter — confession and unsworn statement — substitution of conviction and sentence.
23 November 2023
The applicant's rape conviction and 25-year sentence upheld: corroborative medical and eyewitness evidence and gang-rape aggravation justified the outcome.
Criminal law — Rape — Corroboration by distressed condition, medical report and eyewitnesses; identification and alibi; appellate review of sentence; gang-rape as aggravating factor.
23 November 2023
The appellant failed to establish entitlement to security for costs; only the extraneous remarks in the High Court ruling were set aside.
Civil procedure — Security for costs — Criteria and discretion to order security; Order XL r.7 High Court Rules and Order 23 (White Book) considerations; weighing stifling of litigation versus recovery of costs; residence and change of address; disposing on documents under Order XXX r.6(A) and consent; appellate review of extraneous findings.
23 November 2023
Court refused no‑case‑to‑answer; found prima facie case of contempt against three alleged contemnors for breaching the ex parte stay.
Civil contempt — committal proceedings — sufficiency of Notice of Motion and supporting affidavit — service and penal notice issues previously determined — prima facie test for case to answer — evidence of attempted takeover, PACRA changes and bank letter constituted prima facie contempt.
23 November 2023
Appeal against murder conviction and capital sentence dismissed; provocation and extenuating circumstances not established.
Criminal law — Murder — Credibility and corroboration of witnesses; Suspect witness rule — Warn-and-caution/confession statements not evidential unless produced; Provocation — elements (provocative act, loss of self-control, proportionate retaliation) required for manslaughter or mitigation.
23 November 2023
Appeal over allocation of subcontract payments and judge’s intrusive conduct; gate motor cost properly deducted from contractor’s balance.
Construction/subcontract — allocation of payments between concurrent projects — admissibility and weight of payment vouchers; Civil procedure — judicial intervention during trial and proper role of judge in examining witnesses; Contract law — deduction/set-off for contract items not performed (gate motor); Appeal — scope for disturbing trial findings of fact where perverse or unsupported by evidence.
23 November 2023
Applicant failed to show satisfactory cause or a prima facie defence to set aside default judgment; appeal dismissed with costs.
Civil procedure – setting aside default judgment; appearance and defence to counterclaim – Order XI(1)(3) HCR; obligation to file within prescribed time; arguable defence requires prima facie evidence (Clayton test); bare denial insufficient; inexcusable delay and duty to monitor counsel.
23 November 2023
Frustration of a development project does not discharge mortgage repayment obligations nor stop interest; appeal dismissed.
Contract law – frustration of performance of a land-development financing facility; Mortgages – limited effect of frustration on borrower’s personal covenant to repay and on running interest; Estoppel/waiver – irrevocable undertaking and third‑party payments did not extinguish mortgage or create novation; Civil procedure – discretion on period for redemption and foreclosure.
23 November 2023
Impecuniosity does not justify extension under section 85(3); settlement talks do not suspend the 90‑day limit.
Industrial and Labour Relations Act s85(3) – extension of time – discretion – sufficiency of reasons – impecuniosity not a valid ground – ex curia/settlement discussions do not suspend statutory time limit – promptness of application required.
23 November 2023
Recent-possession alone was insufficient to uphold convictions for four appellants; ballistic and recovered-property evidence upheld two convictions.
Criminal law – aggravated robbery – circumstantial evidence – recent possession doctrine – inference of guilt – ballistic linkage – admissibility and weight of police seizure evidence – appellate review of inconsistencies.
23 November 2023
Deliberate strangulation and suffocation established malice; the appellants' appeal against murder convictions and death sentences dismissed.
Criminal law — Murder — Malice aforethought — Strangulation and suffocation as proof of intent/knowledge — Manslaughter distinguished — Extenuating circumstances under s.201 Penal Code — Evidence and sentencing.
23 November 2023
Appeals largely dismissed; 2nd appellant's conviction quashed due to unsafe identification by a single fleeting witness.
Criminal law – identification evidence – eyewitness reliability; single identifying witness and fleeting glimpse – mistaken identification – suspect witnesses and potential bias – fairness of identification parade – alibi credibility – common purpose liability.
23 November 2023
Extension to seek leave to appeal refused for failure to justify delay and show a meritorious intended appeal.
Court of Appeal — Extension of time to seek leave to appeal to the Supreme Court — Order 8 rule 3(1)(a) — Court of Appeal Act s.13 meritorious threshold — justification for delay — repetition of previously determined grounds — dismissal for want of merit.
23 November 2023
Appellate court reverses wrongful/unfair termination finding, holding employer’s probationary assessment and dismissal for misconduct justified.
Industrial and Labour Relations Act – jurisdiction and delay; Civil procedure – affidavit evidence v viva voce evidence; Employment law – probationary assessment (s27(2) Employment Code Act); Employment law – valid reasons for termination (s52(1) Employment Code Act) – misconduct, dishonesty and misuse of company resources; Appellate review – unbalanced evaluation of evidence; Quantum of damages – departure from normal measure (academic where termination justified).
23 November 2023
Appellant failed to prove misrepresentation or undue influence; equitable mortgage and foreclosure orders upheld; COVID-19 did not alter contractual repayment obligations.
Contract law – loan agreements – requirement to plead fraud/misrepresentation with particularity; borrower’s obligation to obtain independent legal advice (distinguished from guarantor); COVID-19 does not automatically vary contractual repayment obligations; equitable mortgage by deposit of title deeds – foreclosure, delivery and sale; interest awards – High Court Rules and Judgment Act.
22 November 2023
Renunciation by a co-administrator can vest sole capacity in the remaining administrator to prosecute an appeal; capacity is for the appeal, not preliminary objection.
Succession law – joint administrators – capacity to sue and appeal – renunciation of administratorship – Section 20 Intestate and Testate Succession Act – preliminary objection vs merits.
22 November 2023
Appellate court set aside High Court ruling after finding interlocutory matters were previously determined and procedural errors occurred.
Civil procedure – interlocutory applications – res judicata – re‑determination of matters already decided by Deputy Registrar and Judge – notice of intention to raise preliminary issues – setting aside High Court Ruling.
22 November 2023
A court should not refer parties to arbitration where the existence or validity of the contract containing the arbitration clause is disputed.
Arbitration Act s.10 – stay and refer to arbitration – court must be satisfied arbitration agreement valid; Arbitration clause separability – limits where underlying contract is disputed; Allegations of fraud/forgery/illegality – disputes as to existence of contract to be tried, not pre‑determined at interlocutory stage; Referral to arbitration inappropriate where agreement is contested.
22 November 2023
Interest on judgment must be computed per annum under Order XXXVI Rule 8; monthly computation was erroneous.
Interest on judgment — computation per annum under Order XXXVI Rule 8; Registrars' assessment — requirement to state reasons; Judgments Act — rate after judgment (Bank of Zambia policy/lending rate); inclusion of unpaid leave in principal; proper formula for interest calculation.
22 November 2023
Part payment can convert a stated "intent" into a binding land sale contract; unresolved triable issues remitted for trial.
Contract of sale of land – Statute of Frauds s.4 – written memorandum versus statement of intent – part payment/consideration converting intent into binding contract – preliminary determination inappropriate where triable issues remain – remittal for trial.
22 November 2023
Res gestae wrongly admitted, but admissible leading and circumstantial evidence sustain the murder conviction.
Criminal law — Evidence: res gestae/dying declarations — contemporaneity and spontaneity required; Leading and demonstration — warning and voluntariness; Circumstantial evidence — discovery of real evidence and inference of guilt; Murder vs manslaughter — malice aforethought.
22 November 2023
Contract expired and was not extended; no quantum meruit recovery without evidence of requested services or benefit.
Contract law – expiry by effluxion of time – renewal negotiations – implied or tacit extension by conduct; Quantum meruit – requirement of request/benefit and implied promise to pay; Evidence – negotiation correspondence and scope of contracted services; Remedies – dismissal where no post-expiry benefit shown.
22 November 2023
Order 30 Rule 1 permits appointment of a receiver and ancillary injunctions; Corporate Insolvency Act s.4 pertains to charged property only; appeal dismissed.
Civil procedure — appointment of receiver — Order 30 Rule 1 (Rules of the Supreme Court) governs mode of application and ancillary injunctions; Corporate Insolvency Act (sections 4–5) applies to receivers over charged property; unsecured debts do not engage section 4; late filing of respondent's heads expunged; appeal overtaken by subsequent default judgment and garnishee order.
22 November 2023
Refusal of an adjournment was defensible, but immediate dismissal for want of prosecution was excessive and set aside.
Civil procedure – Adjournments – discretionary refusal where no compelling or exceptional circumstances shown – formal notice requirements – failure to file notice and mere courtesy to opposing counsel insufficient – Dismissal for want of prosecution is a draconian remedy to be exercised sparingly; rules permit costs/hearing fee rather than immediate striking out – balance between right to be heard and expeditious disposal of cases.
22 November 2023
Entry of judgment on admission was premature where admissions were unclear, evidence untested and triable issues existed.
Commercial Division — Judgment on admission — Order 53 rule 6 — Admissions must be clear, unequivocal and unconditional — Burden of proof before entering judgment without trial — Scheduling conference not a substitute for tested evidence — Limitation/part-payment issues to be resolved on evidence at trial.
22 November 2023