Court of Appeal of Zambia - 2023 December

18 judgments
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18 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