Court of Appeal of Zambia - 2023 April

25 judgments
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25 judgments
Citation
Judgment date
April 2023
An action to recover land was statute-barred because the cause of action accrued at the 2004 transfer and limitation ran notwithstanding the deceased's death.
Limitation of actions – recovery of land – accrual of cause of action at time of challenged transfer – personal representatives stand in deceased’s shoes for limitation purposes – fraud or mistake must be specifically pleaded to delay limitation – adverse possession irrelevant where registered title exists.
29 April 2023
Personal representatives cannot sue to recover land after the 12‑year limitation where the right to challenge accrued during the deceased's life.
Limitation of actions – recovery of land – accrual of cause of action when transfer effected – personal representatives stand in deceased's shoes for limitation purposes – registered title and adverse possession – annulment of marriage does not automatically vitiate certificate of title.
26 April 2023
Unauthenticated, unsupported sales journals were insufficient to prove special damages; appeal dismissed.
Civil procedure – assessment of damages; special damages – burden of proof and requirement of corroboration; authenticity of handwritten sales journals; appellate restraint on interfering with discretionary damage awards.
26 April 2023
Failure to file record within extended time was inexcusable; full court discharged single-judge order and dismissed appeal for want of prosecution.
Civil procedure — Application to vary/discharge single judge's ruling — Section 9(b) Court of Appeal Act and Order 10(2)(8) CARs — Dismissal for want of prosecution — Birket v. James test — Inordinate and inexcusable delay — Effect of conducting applications out of sequence.
26 April 2023
Failure to show irreparable harm from administratrix holding estate shares; injunction denied and appeal dismissed.
Intestate succession – interlocutory injunction – irreparable injury and adequacy of damages – risk of dissipation of estate shares – Companies Act s.190 transmission of shares – administratrix' duty to account.
26 April 2023
A limitation defence is jurisdictional, may be raised anytime, and the dismissal was time-barred and correctly upheld.
Limitation of actions – accrual of cause of action – statute-barred defence is jurisdictional and may be raised at any time – appellate review of factual findings – dismissal on jurisdictional grounds.
26 April 2023
Appeal dismissed: action not res judicata, not statute‑barred; third‑party/equitable mortgage proven; foreclosure upheld.
Civil procedure – res judicata – when prior judgments must have determined the same specific security; Limitation law – actions to recover money secured by mortgage governed by 12‑year limitation; Property/mortgage law – equitable mortgage may be constituted by deposit of title deeds; jurisdiction and functus officio – court may hear matter where specific security not previously adjudicated.
26 April 2023
Purchase order must be read with the accepted quotation; defective ladders breached merchantability, allowing the respondent to reject payment.
Contract formation – purchase order versus tender/accepted quotation; Parol evidence rule – exception where written instrument is not whole agreement; Sale of Goods Act s.14 – implied condition of merchantable quality and fitness for disclosed purpose; Rejection of goods – oral notice can be sufficient; Appellate review – factual findings not disturbed absent misapprehension.
26 April 2023
Failure to authenticate sales journals defeated the claim for special damages; appellate court upheld token award and dismissed appeal.
'Special damages' — proof and standard of certainty; authenticity of accounting records; handwritten sales journals lacking receipts or bank deposits; appellate review of damages assessments; token awards where evidence is meagre.
26 April 2023
Whether refusing an interlocutory injunction was justified where administratrix held ascertainable estate shares allegedly risking irreparable harm.
Interlocutory injunction — irreparable harm — adequacy of damages; Administration of estate — transmission of shares — s.190 Companies Act inapplicable; Risk of dissipation — requirement to plead threats; Appeal procedure — confined to grounds in memorandum of appeal.
26 April 2023
Extension of time refused where applicant failed to justify delay and show the intended appeal met statutory merits threshold.
Criminal appeal procedure – extension of time to apply for leave to appeal – applicant must justify delay and demonstrate intended appeal meets statutory threshold (point of law of public importance, public interest, reasonable prospects of success, or other compelling reason) – change of DPP not a sufficient excuse where Acting DPP available.
26 April 2023
Court of Appeal affirms that review under Order XXXIX(1) is discretionary, requires sufficient grounds, and upheld dismissal for premature, multiplicity-based proceedings.
+ Civil procedure – Review of own judgment – Order XXXIX(1) High Court Rules – discretionary power – sufficient grounds required; one ground: material evidence not available despite due diligence. + Civil procedure – Multiplicity of actions – pending subordinate court appeal arising from same facts – premature proceedings and abuse of process. + Costs – award to successful party not a ground for review; remedy by appeal.
25 April 2023
Delay of one year nine months in serving the Record of Appeal without court-ordered extension justified dismissal for want of prosecution.
Civil procedure – Appeal procedure – Service of Record of Appeal and heads of argument – Order X r.9(9) – Requirement to serve within 14 days – Failure to obtain extension under Order XIII r.3 – Service out of time null and void – Dismissal for want of prosecution – Costs.
25 April 2023
Members were jointly liable and mortgage securities enforceable despite the association being the contractual borrower.
Civil procedure – originating summons – fraud allegation must be specifically pleaded and particularised; Loan law – association as borrower but members bear joint and collective liability under contract and implementation rules; Security law – mortgage deeds and personal guarantees enforceable where implementation rules required collateral; Foreclosure – foreclosure judgment upheld.
25 April 2023
Whether a trial judge properly refused review under Order XXXIX(1) given alleged fresh evidence and a pending related appeal.
Civil procedure – Review under Order XXXIX(1) – discretionary power requiring sufficient grounds; fresh evidence (unavailable despite due diligence) a recognised ground but not the only one – Prematurity and multiplicity of actions where parallel appeal pending – Costs awarded to successful party not ground for review.
25 April 2023
25 April 2023
Public funds under the Environmental Protection Fund are subject to the State Proceedings Act 6% interest cap; 13% award set aside.
State Proceedings Act s20 — statutory cap on interest payable from public funds (6%); Public Finance Act — definition of "general revenues" and "public funds"; Environmental Protection Fund monies held to be public funds; assessment of post‑judgment interest on foreign currency judgment; appellate review of erroneous interest awards.
24 April 2023
Whether accrued pension rights survive summary dismissal and whether awarding them alongside damages constitutes double compensation.
Employment law – unfair and wrongful dismissal; disciplinary sanctions – proportionality; collective agreement applicability; accrued pension rights and portability; pension scheme regulation; remedies distinctness (accrued benefits vs damages).
24 April 2023
Presence in a group and an admitted co-accused's confession do not suffice to establish common purpose for murder without cogent supporting evidence.
Criminal law — Common purpose doctrine — Sufficiency of circumstantial evidence — Res gestae hearsay exception — Identification and participation required for joint liability.
23 April 2023
Presence with an assailant and an unspecific res gestae statement do not establish common purpose; convictions unsafe.
Criminal law — Common purpose — Evidence — Res gestae — Circumstantial evidence — Standard for inference of guilt
23 April 2023
Court granted stay of execution pending appeal to preserve the chiefdom's status quo without prejudice to parties.
Civil procedure — Stay of execution pending appeal — Discretionary remedy; good and sufficient grounds required; court may preview prospects of appeal; preserve status quo; chiefdom succession — nullification of installation; caretaker chief.
13 April 2023
Whether an agreement to submit disputes to international arbitration ousts court jurisdiction when the clause is alleged defective.
Arbitration Act s10 — validity and interpretation of arbitration clauses — court must ascertain whether clause is null, void, inoperative or incapable of performance — wording of clause to be studied (Audrey Nyambe) — contra proferentem only where ambiguity persists — stay and referral to international arbitration (seat London).
6 April 2023
Court reversed disciplinary findings, found procedural breach under Employment Code, awarded monetary damages and refused penal gratuity clause enforcement.
Employment law – summary dismissal – role of courts vs disciplinary tribunal – natural justice and statutory right to be heard (Employment Code s.52(3)) – admissibility/corroboration of leave approval evidence – unenforceability of penal gratuity clause.
6 April 2023
Whether a network-license holder is vicariously liable for an independent contractor's trespass absent a statutory non-delegable duty.
Vicarious liability – independent contractor – trespass to land – statutory duty (Section 63 ICT Act) – non-delegable duty – assessment of evidence.
5 April 2023
SI 58 removed conditional appearances; defendants must file a memorandum of appearance and defence before challenging a writ's validity.
Civil procedure – High Court Rules (Order 11 HCR) – Statutory Instrument No. 58/2020 deleting conditional memorandum of appearance – requirement to file memorandum of appearance and defence before applying to set aside writ for irregularity or want of jurisdiction – Order 11/21 HCR (setting aside service) preserved.
5 April 2023