Court of Appeal of Zambia - 2023 October

41 judgments
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Results. 41 judgments found.

41 judgments
October 2023
A lender who reasonably verified documents was not primarily liable for third-party impersonation fraud, but refund reduced by refinance payment.
  • Banking law — fraud by impersonation — forensic handwriting evidence — duty of reasonable care and verification by credit provider — when bank is put on inquiry — restitution between innocent parties — set-off for refinancing payment.
30 October 2023
Whether leave is required for appeal against an open Court judgment and the jurisdictional effect of failure to obtain leave.
  • Civil appeal — Leave to appeal — Court of Appeal Act s22–23 — Open Court judgment; jurisdiction — Procedural form defects — Interpretation & General Provisions Act s47 — Statutory instrument inconsistent with Act void to extent of inconsistency (s20(4)); costs for withdrawn interlocutory application.
30 October 2023
Appellate court set aside unpleaded finding of contributory negligence and dismissed other appeal grounds, including unsupported PPE and benefit claims.
  • Employment law — termination and payment in lieu — appellate review of factual findings; Pleadings — requirement to plead contributory negligence; Negligence — duty to prove inadequate PPE with supporting evidence.
30 October 2023
Court dismissed appeal: disciplinary process was fair, sufficient facts supported gross negligence dismissal, emotional injury claim failed.
  • Employment law — Summary dismissal for alleged gross negligence — Disciplinary procedure and natural justice (audi alteram partem) — Composition of appeal tribunal and impartiality — Substratum of facts and continuous employment — Limited judicial review of domestic disciplinary findings — Emotional injury damages contingent on wrongful/unfair dismissal.
30 October 2023
Whether written documents satisfied Statute of Frauds and warranted specific performance, fraud not sufficiently proved.
  • Contract of sale v loan — Statute of Frauds s.4 — written memorandum must contain names, subject matter and consideration — allegations of fraud/forgery must be clearly pleaded and proved to a higher standard — specific performance available for land where damages inadequate.
27 October 2023
A work-capacity certificate by a registered practitioner can suffice; short premature medical termination not wrongful if entitlements paid.
  • Employment law — termination on medical grounds — wrongful dismissal vs termination — contractual clause requiring six months and a medical report — work-capacity certificate as medical report — damages for wrongful dismissal — Employment Code Act considerations.
27 October 2023
A purchaser aware of ongoing disputes before obtaining title cannot claim bona fide purchaser without notice.
  • Land law — bona fide purchaser for value without notice — constructive and actual notice — prior possession and equitable interest — cancellation of certificate of title — necessity to plead and strictly prove fraud or procedural impropriety — role of Registrar/Ministry and caveats.
27 October 2023
The court held that failure to dispose within one year does not divest the Industrial Relations Division of jurisdiction; dismissal set aside.
  • Industrial and labour law — one-year disposal rule — jurisdiction — purposive interpretation; Order 14A applications — determination on point of law without full trial; costs in Industrial Relations Division — rule 44(1) prohibition unless unreasonable conduct.
27 October 2023
Failure to verify title at the Lands Registry defeats bona fide purchaser defence; registered title prevails absent proven fraud.
  • Land law — registered title — evidential effect of Certificate of Title; bona fide purchaser for value without notice — duty of due diligence and Lands Registry search; sale by personal representative — court authority required; fraud allegations — requirement for particularization and proof.
27 October 2023
Whether dismissal was substantiated by evidence and whether costs could be awarded under Rule 44.
  • Employment law — unfair dismissal — disciplinary and grievance code — proof/substratum of facts required to justify dismissal — court's role vis-à-vis domestic disciplinary tribunals — costs under Industrial and Labour Relations Rules (Rule 44).
27 October 2023
Failure to charge or hear an employee before dismissal contrary to s.52(3) Employment Code renders the dismissal unfair despite substantive misconduct.
  • Employment law — unfair dismissal — mandatory hearing under s.52(3) Employment Code; contractual licence requirement for pilots; procedural breach (failure to charge/hear) renders otherwise justified dismissal unlawful; enhanced damages for high-handed termination.
26 October 2023
Order for possession inconsistent with earlier judgments set aside; matter remitted to Registrar for assessment and parties restrained from interfering with property.
  • Civil procedure — Order 39 High Court Rules — review limited to fresh material evidence discovered since judgment; slip rule cannot introduce fresh evidence on appeal; correction of clerical errors should be sought in the court that made the order; injunctions require reasoned consideration and preservation of status quo pending accounting; remittal to Registrar for assessment.
26 October 2023
Court cancelled a certificate of title procured by fraud/impropriety and restored the land to the applicant.
  • Land law — offer to purchase and acceptance — lapse of offer for non-payment — admissibility and weight of Land Information Management System records — cancellation of certificate of title procured by fraud or impropriety — misrepresentation as sitting tenant — standards for interfering with trial court findings of fact.
26 October 2023
Bank unlawfully and prematurely restricted customer's account under CDDP, causing liability for the dishonoured cheque.
  • Banking law — Customer due diligence — Financial Intelligence Centre Act — CDDP mandatory mitigation period (150 days) — Unilateral account restriction — Reliance on unpleaded contractual clause — Wrongful dishonour of cheque — Damages.
26 October 2023
A consent judgment is binding and can only be varied or set aside by commencing fresh proceedings, not by a simple application.
  • Civil procedure — Consent judgments — binding effect of consent orders — variation or setting aside requires fresh action — deficient reasons in orders — parties bound by terms of consent orders.
26 October 2023
A purposive reading of the IRD one-year rule does not oust jurisdiction; delayed matters should be reheard, not dismissed.
  • Industrial and Labour Relations Act s.85(3)(b)(ii) — one-year disposal rule — jurisdiction — purposive statutory interpretation — delay attributable to court — remittal for rehearing — costs in IRD (Rule 44(1)).
26 October 2023
The Court declined a stay pending appeal, finding the appeal raised mainly factual issues unlikely to succeed.
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25 October 2023
Whether restructuring or promotion determines calculation of back-pay, and whether acting allowances and overtime were properly accounted for.
  • Employment law — assessment of judgment sum — restructuring v promotion — Collective Agreement application — accounting for acting allowances — adequacy of registrar’s reasoning on assessment — overtime calculation (160 v 365 factor) and legitimate expectation.
25 October 2023
Application for stay of execution pending appeal dismissed for lacking prospects of success and undue prejudice to respondent.
  • Civil procedure — Stay of execution pending appeal — Discretionary remedy — Prospects of success on appeal — Prejudice to successful party — Section 9(b) Court of Appeal Act — Relevant authorities: Sonny Paul Mulenga; Carmine and Watson Nkandu Bowa; Zambia Revenue Authority v. Post Newspaper
25 October 2023
The Local Authorities Superannuation Fund, not the employers, is liable for eligible retirement benefits; Fund joined and matter remitted.
  • Pension law — Local Authorities Superannuation Fund Act s28 — entitlement to retirement benefits on retrenchment; joinder of interested party; redundancy payments versus retirement benefits; payroll and post-retrenchment salary increments.
25 October 2023
A Mareva injunction against the respondent was set aside for material non‑disclosure, abuse of process, and no demonstrated risk of asset dissipation.
  • Civil procedure — Mareva (freezing) injunction — requirements: good arguable debt and real risk of asset dissipation — duty of full and frank disclosure — abuse of process where interlocutory freezing order sought despite active appeal dealing with same subject matter — powers of single judge under s.9(b) Court of Appeal Act to be varied by full Court.
25 October 2023
Court set aside a 30% payment condition and granted a stay pending appeal to protect appellants' proprietary interests.
  • Stay of execution pending appeal; conditional stays requiring payment into court; 30% payment as prerequisite; prospects of success and irreparable harm; access to justice; proprietary rights in land and mining interests.
25 October 2023
Condition precedent in fixed-term contracts prevented automatic renewal; Employment Code did not render termination unlawful here.
  • Employment law — fixed-term contracts — condition precedent — renewal by conduct — whether allowing continued work extends contract — applicability/retrospectivity of Employment Code Act 2019 — damages for unfair termination.
25 October 2023
Challenge to a business rescue resolution under section 22(1) is not barred by the moratorium and may be brought by Originating Summons.
  • Corporate Insolvency Act — Business rescue — Sections 21, 22, 25 and 43 — Moratorium not applicable to pre-plan challenges under s22 — Commencement by Originating Summons — Business Rescue Administrator does not automatically replace company as party — Citation of company in its own name.
23 October 2023
A consent judgment must be challenged by appeal or by fresh action in the court that issued it, not by a fresh High Court action.
  • Civil procedure — Consent judgment — Setting aside consent judgment — Remedy by appeal or fresh action — Fresh action to set aside must be brought in the court that sealed the consent judgment; High Court jurisdiction subject to procedural limits.
23 October 2023
Psychiatric evidence of an atypical seizure disorder met diminished responsibility, reducing murder convictions to manslaughter.
  • Criminal law — murder — psychiatric evidence — expert opinion may be relied upon if based on logical inferences — diminished responsibility (s12A Penal Code) — epileptiform/atypical seizure disorder can constitute abnormality of mind — burden and standard for diminished responsibility — appellate substitution to manslaughter (s199).
21 October 2023
Leave to appeal denied; issues on piercing the corporate veil lacked public importance and stay discharged.
  • Appellate procedure — leave to appeal to Supreme Court (s.13(3)) — requirements: point of law of public importance, reasonable prospects of success, compelling reasons; corporate veil — whether piercing raises public law question; procedure — affidavit address defect (form v substance) and curable deviations (Interpretation and General Provisions Act s.47); security for costs must be sought by separate application; Order XIII Rule 5 inapplicable to post-judgment preliminary objections.
20 October 2023
Appeal succeeds: dismissal for procedural irregularity set aside; late demand letter deemed curable with leave and matter remitted.
  • [Defamation] Procedural irregularity — Order 3 r.2 (interlocutory) cannot be used for final dismissal; [Procedure] failure to enter appearance and defence; [Pre-action requirement] Order VI r.1(d) — letter of demand; [Service] service on director treated as service on company; [Curable defects] non-compliance may be curable with leave; [Remittal] matter sent back for rehearing.
19 October 2023
Retirement in the national interest must state the specific government-policy reason; nondisclosure renders the termination unlawful, limited damages awarded.
  • Employment law — Retirement in the national interest — Clause 38(e) and Regulation 29(c) — Requirement to disclose whether retirement is for redeployment outside public service or specific government policy reason — Failure to disclose renders termination unlawful — Reinstatement exceptional; limited damages appropriate.
13 October 2023
Termination for incapacity held wrongful for failing to give contractual notice; damages limited to one month's pay.
  • Employment law — incapacity and sick leave (Employment Code Act s.38) — redeployment vs. termination — contractual notice — measure of damages for wrongful termination — costs under Industrial Relations Court Rules r.44.
13 October 2023
13 October 2023
Conviction unsafe where prosecutrix’s uncorroborated evidence relied on an improperly admitted police confession.
  • Juveniles Act s122(1) — reception of child evidence on oath; Voir dire — no prescribed questions, assessment by answers and demeanor; Criminal Procedure Code — plea procedure and consequences of not retaking plea; Admission of confessions — accused should be asked about objections before production; Corroboration requirement for child evidence — conviction unsafe if corroboration is improperly admitted.
12 October 2023
Appeal partly allowed: Registrar to assess arrears; trial judge wrong to overrule earlier High Court on aligning rents to US dollar; parties bear own costs.
  • Landlord and tenant — determination of standard rent — allocation of valuation costs; assessment of rent arrears — Registrar vs independent assessor; requirement of evidence for damages for loss of business; stare decisis between judges of co-ordinate High Court jurisdiction — prohibition on aligning local rents to foreign currency and effect of statutory instruments.
11 October 2023
Late, extensive amendments that recast a claim and substitute a party lacking original capacity were refused for prejudice and abuse of process.
  • Civil procedure — Amendment of pleadings after trial commencement — Amendment takes effect from original issue date — Substitution of party lacking capacity at commencement — Late amendments that recast the claim and seek to cure cross-examination damage — Lateness, nature of amendment, prejudice and justice as discretionary factors — Costs may be inadequate compensation.
10 October 2023
Appeal dismissed: no proven extenuating circumstances (provocation/intoxication) to reduce death sentence.
  • Criminal law — Murder — Sentence — Extenuating circumstances — Provocation and intoxication — Failed defences — Ballistic evidence linking issued service rifle to fatal shot — Conduct of trained police officer relevant to culpability.
10 October 2023
Appeal: aggravated robbery conviction substituted to causing grievous harm due to insufficient proof of violence used to effect the theft.
  • Criminal law — aggravated robbery — elements: violence contemporaneous with stealing — proof beyond reasonable doubt; identification evidence and inconsistencies in witness statements; substitution to lesser offence (causing grievous harm).
10 October 2023
Circumstantial and medical evidence sufficed to corroborate commission and identity; conviction for defilement upheld.
  • Criminal law — Defilement — Circumstantial evidence — Corroboration of commission and identity — Opportunity as corroboration — Medical evidence confirming vaginal trauma and presence of semen — Reasonable inference of guilt.
10 October 2023
DPP may appeal findings of fact that lack any evidential basis; appellate court can overturn such credibility findings.
  • Criminal law — DPP appeals under s.321A — scope limited to points of law; finding of fact unsupported by evidence is appealable as law (Ng'andu principle) — Appellate interference with credibility findings where trial judge erred in evaluation — Possession of prohibited trophy (ivory) — joint possession inference
10 October 2023
Allegation of forgery not proved; plaintiff entitled to specific performance and appeal dismissed.
  • Contract law — specific performance — equitable remedy available where contract established; Burden and standard of proof — allegations of fraud/forgery must be clearly pleaded and proved on a higher standard; Evidence — mere denial of signature insufficient without forensic or corroborative proof; Transfer of title — claim that seller lacked title fails where forgery allegation not proved.
2 October 2023
Applications under section 9(b) must be brought within a reasonable time; affidavit paragraphs were factual and not expunged.
  • Civil procedure — Section 9(b) Court of Appeal Act — application to vary/discharge single judge decisions must be filed within a reasonable time (no strict 10-day rule); Mareva injunction — setting aside; affidavits in interlocutory proceedings — factual statements and statements of belief permissible; expungement only for truly extraneous or argumentative matter.
2 October 2023
Whether the respondent fairly discharged the applicant, burden under section 52, sufficiency of particulars, and terminal benefits.
  • Employment law — dismissal/discharge — burden of proof under s52 Employment Code; adequacy of particulars/natural justice; procedural irregularities do not invalidate dismissal where dismissible offence established; unpleaded remedies not awarded.
2 October 2023