Court of Appeal of Zambia - 2023 July

16 judgments
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Results. 16 judgments found.

16 judgments
July 2023
A judgment on assessment under a consent order renders the registrar functus officio; appeal dismissed for lack of jurisdiction.
  • Civil procedure — consent order following mediation — assessment of damages by District Registrar — judgment on assessment — functus officio — jurisdiction — proper remedy is appeal of Registrar's assessment; variation of consent order requires fresh action alleging fraud, mistake or misrepresentation.
31 July 2023
The respondent cannot deduct a client's judgment proceeds for unpaid fees; a compliant bill must precede fee-recovery litigation.
  • Legal practitioners — deduction of fees from client’s judgment proceeds — Kuta Chambers precedent — Order 50 Rule 2 (bill before suing) — taxation of costs — duty to render itemized bill and obtain instructions — prohibition on unilateral lien on client judgment funds.
26 July 2023
Changes to organisational structure made without the Authority’s Board were null and void, but termination by notice under the contract was lawful.
  • Administrative law — Statutory body governance — Authority of Board of Trustees over structure and appointments — Director-General limited to day-to-day administration; changes made without properly constituted Board are null and void; distinction between unilateral variation of basic terms (redundancy) and lawful termination by contractually provided notice
26 July 2023
A collective agreement effective during fixed-term contracts can vary individual contract terms, entitling employees to the revised 35% gratuity.
  • Collective agreements — effect on individual employment contracts — variation of contractual terms by collective agreement in force — end-of-contract gratuity computed at revised rate on last drawn salary; no retrospective alteration of past entitlements but lawful variation from effective date.
26 July 2023
A foreign-resident plaintiff must show fixed, permanent assets in Zambia to avoid an order for security for costs.
  • Civil procedure — Security for costs — Discretionary relief under Order XL r.7–8 (High Court Rules) and Order 23 (Rules of the Supreme Court) — Factors: residence abroad, power of attorney, enforcement difficulty, and existence of fixed, permanent assets within jurisdiction — Evidential burden on foreign plaintiff to show substantial property available for costs.
26 July 2023
Unproven allegations of fraud, misrepresentation or secret meetings do not suffice to set aside an arbitral award under s.17.
  • Arbitration Act s.17 — Setting aside arbitral award — Fraud, corruption or misrepresentation — Distinction between merits review (appeal) and grounds for setting aside — Requirement of tangible evidence; Procedural irregularity and proof of improper conduct.
26 July 2023
Appeal dismissed: dismissals unfair; first respondent deemed retired; second awarded 24 months’ salary; lower court costs set aside.
  • Employment law — wrongful and unfair summary dismissal — communication of internal policy — delegated approval/splitting transactions — procedural fairness and reasons on appeal under Disciplinary Code — remedies: retirement deeming, compensation for unfair dismissal, mitigation for amounts already paid — costs under Industrial Relations Court Rules (Rule 44).
24 July 2023
Appeal succeeds where respondent failed to prove forgery; property declared part of deceased's estate and prior order set aside.
  • Land and registration law — Allegation of fraud/forgery in title transfer — Pleading and proof of fraud requires particularity and a higher standard of proof; handwriting expert evidence where signature disputed — Section 33 & 34 Lands and Deeds Registry Act; Statute of Frauds — requirement for deed evidence; Joinder of interested third parties (CEEC) when title deeds held as loan collateral; Cohabitation does not automatically create marital rights.
24 July 2023
Fraud in transfer of title must be proved with cogent evidence; unchallenged pleadings do not substitute for required proof.
  • Property law — title and certificate of title — proof of fraud and forgery — higher standard of proof for fraud — pleading and proof — cohabitation versus marriage — joinder of interested third parties (CEEC) holding title deeds.
24 July 2023
Allegations of fraud in land transfers require particularised proof; absence of evidence justified setting aside the return-of-title order.
  • Land and Deeds Registry Act — Certificate of title conclusive but defeasible for impropriety or fraud; Fraud/forgery allegations must be pleaded with particularity and proved to a higher standard; disputed signatures — forensic/handwriting evidence ordinarily required; Cohabitation does not necessarily create matrimonial rights; Joinder of interested parties (CEEC) where title deeds are held as collateral.
24 July 2023
Whether alleged encroachment was proved without survey/boundary evidence; administrative letter alone was insufficient.
  • Land law — alleged encroachment on state land — burden of proof; need for survey diagram or boundary evidence; inchoate interest and locus standi without formal offer; insufficiency of administrative letter as sole proof of encroachment; costs follow the event.
21 July 2023
Appeal upheld: court must grant special leave before reviewing out‑of‑time applications; delay unexplained and "fresh" evidence not established.
  • Civil procedure — Review and special leave under Order 39(1)–(2) HCR — two‑stage procedure; delay justification required. — Fresh evidence threshold for review — discoverability and material effect. — Companies in liquidation — execution and priorities. — Compliance with Order 30 rule 3A(3): affidavit in opposition; regulatory nature and adjournment remedy.
21 July 2023
The respondent proved fair dismissal for dishonest conduct; the appellant's wrongful dismissal claim was dismissed.
  • Employment law — wrongful dismissal — s.52(5) Employment Code (burden on employer) — disciplinary procedure — substratum of facts required to support dismissal — dishonest conduct; failure to follow revenue-handling procedures.
21 July 2023
Zambian (common) law does not recognize a general duty to negotiate in good faith; related damages are unavailable.
  • Contract law — pre‑contractual negotiations — duty to negotiate in good faith — unenforceable in common law (Walford v Miles) — MOU non‑binding — damages unavailable — estoppel and civil‑law authorities inapposite.
21 July 2023
A single Judge dismissed third party's application for leave to appeal where out-of-time review lacked sufficient reasons and realistic prospects.
  • Civil procedure — Leave to appeal — Single Judge jurisdiction to grant leave where High Court refused; Review applications — Order XXXIX Rule 2 requires review within 14 days or special leave; Delay and failure to disclose when applicant became aware of order fatal; Leave requires prima facie realistic prospects of success; Abuse of process where third party seeks to revive action not pursued by substantive parties.
18 July 2023
Vacant possession ordered after rescission; respondents’ improvements to be assessed and reimbursed; foreign-currency interest fixed at 4%.
  • Contract rescission — restitution and prevention of unjust enrichment; improvements to land — proof and assessment of value; licence vs lease — gratuitous licence; mesne profits inapplicable to licensor/licensee; foreign-currency judgment interest — LIBOR-derived/low rate (substituted at 4%); enforcement of judgment and vacating possession.
17 July 2023