Court of Appeal of Zambia - 2023 January

13 judgments
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13 judgments
Citation
Judgment date
January 2023
Convictions quashed where sole suspect eyewitness was uncorroborated and juveniles were improperly treated at sentencing.
Criminal law – murder – suspect eyewitness – requirement for independent corroboration to exclude false implication; proof of malice aforethought; juvenile procedure – age inquiry and parental attendance; mis‑sentencing after ocular observation.
25 January 2023
Circumstantial murder conviction unsafe where suspect witnesses' evidence lacked independent corroboration.
Criminal law – Circumstantial evidence – Suspect witnesses – Danger of false implication – Need for independent corroboration – Standard: proof beyond reasonable doubt.
25 January 2023
Circumstantial evidence and inadmissible forensic and confession evidence rendered the murder conviction unsafe; appellant acquitted.
Criminal law – murder – circumstantial evidence – requirement that circumstantial strands attain cogency to exclude reasonable innocent inferences; admissibility of confession – voluntariness and duress (handcuffing); admissibility of forensic reports – necessity for the maker/expert to testify; sufficiency of evidence to prove guilt beyond reasonable doubt.
25 January 2023
Whether an uncorroborated circumstantial conviction based on suspect witnesses is safe and sustainable.
Criminal law — Circumstantial evidence — Suspect witnesses and danger of false implication — Need for corroboration before conviction — Conviction unsafe where danger not excluded.
25 January 2023
Age of prosecutrix not proved; defective hostile-witness procedure and unreliable documentary evidence led to acquittal.
Criminal law — Defilement — Age of prosecutrix an essential ingredient — Age must be proved beyond reasonable doubt by parent/guardian or best available evidence — Unsigned affidavit and hearsay school letter inadmissible — Procedure for treating witness as hostile.
25 January 2023
Age of prosecutrix not proved beyond reasonable doubt; conviction for defilement set aside and appellant acquitted.
Criminal law — Defilement — Proof of age as essential ingredient — Best evidence preferably from parent/guardian — Hostile witness procedure — Unsigned affidavit defective — School letter hearsay — Acquittal for failure to prove age beyond reasonable doubt.
25 January 2023
Appellate court increased wrongful dismissal damages, ordered reimbursement and interest, and declined unpleaded reinstatement or exemplary damages.
Employment law — Wrongful dismissal — Breach of public service disciplinary regulations (reg.57, reg.32(c)) — Measure of damages for unlawful dismissal — Exceptions to common-law notice measure — Exemplary damages must be pleaded — Reinstatement relief not entertained when not pleaded.
23 January 2023
Appellate court raised wrongful dismissal damages to 42 months due to oppressive conduct and high unemployment, denying unpleaded relief.
Labour law – Wrongful dismissal – Measure of damages – When courts may exceed common-law notice period; exemplary damages must be pleaded; reinstatement not ordered if not raised below; breach of disciplinary rules and inordinate delay in appeal determination.
23 January 2023
Appellant’s title cancelled for being procured by fraudulent misrepresentation; appeal dismissed, prior orders upheld.
Property law – fraudulent misrepresentation inducing transfer – cancellation of title; Leasehold interests – beneficiary of trust lease; Proof of fraud – documentary and oral admissions; Remedies – rescission of title, refusal of restitution/compensation absent evidence; Costs – follow the event.
11 January 2023
Interlocutory appeals are impermissible in criminal matters; High Court ruling set aside and subordinate trials proceed, second appeal incompetent.
Criminal procedure – interlocutory appeals – interlocutory appeals not tenable in criminal matters; s90(7) CPC – appeal only where Magistrate declines complaint; Court of Appeal Act s15 – leave required for appeal from High Court review; revisionary powers – timing and competency; nullity of High Court interlocutory ruling.
11 January 2023
A general power of attorney does not, as such, require registration under Section 4 to confer locus standi in land proceedings.
Lands & Deeds Registry Act – Registration of documents – Whether a power of attorney must be registered under s.4 – Power of attorney as delegation of authority not transfer of interest; locus standi – registration not required under s.4; Miscellaneous Register s.9(c) – Distinction between s.22 land register printouts and s.23 official certificates of search (conclusive).
11 January 2023
The Court refused the applicant's stay pending appeal, finding no real prospects of success and dismissing the application.
Civil procedure – Stay of proceedings pending appeal – Discretion under Order 10 rule 5 CARs – Appeal does not operate as automatic stay – Stay requires good and convincing reasons and real prospects of success – Issues of res judicata and abuse of process.
10 January 2023
Court confirmed stay of execution pending appeal due to inconsistencies in the lower court's judgment and potential prejudice.
Civil procedure — Appeal and stay of execution — Appeal does not automatically stay execution — Stay granted only on good and convincing reasons — Inconsistencies in lower court judgment may justify stay — Order X Rule 5 CA Rules; Order 47 White Book.
10 January 2023