Court of Appeal of Zambia - 2024 November

37 judgments
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37 judgments
Citation
Judgment date
November 2024
Applicant denied equitable account: stakeholder accounted for funds; court found no duty to probe purchase price and unclean hands.
Equity – Accounting – Scope of accounting party’s duty under Order 43/2 RSC – limited to accounting for monies received and disbursed; Privity of contract – accounting party not obliged to investigate contract price it is not party to; Equity – Clean hands doctrine bars equitable relief where applicant admits misconduct; Civil appellate review – interference with factual findings only where perverse or unsupported by evidence; Payments – bank transfers and receipts can substantiate disbursements.
28 November 2024
A fraud-based action to set aside judgment must target procurement conduct, not re-litigate merits or enforcement steps.
Civil procedure – Setting aside judgment obtained by fraud – Jurisdiction to bring fresh action – Requirement to plead fraud with particularity – Proof of conscious and deliberate dishonesty – Fraud must be material and causally operative – Finality of judgments – Abuse of process where pleadings re-litigate merits or attack enforcement/post-judgment steps.
28 November 2024
Employer must give and substantiate valid operational reasons for termination; traumatic public dismissal attracts enhanced damages.
Employment law — unfair dismissal; operational requirements — requirement to give and substantiate valid reasons; burden on employer; notice clause not an escape; procedural fairness and opportunity to be heard; enhanced damages for traumatic/public dismissal.
28 November 2024
Appeal dismissed: tribunal validly exercised disciplinary powers; insufficient proof of unpaid benefits.
Employment law – disciplinary dismissal – validity and exercise of disciplinary powers – substratum of facts supporting summary dismissal where employee not caught red‑handed; burden of proof for claim of unpaid terminal benefits – contractual entitlements (salary, housing allowance, accrued leave).
28 November 2024
Propounder must dispel suspicious circumstances under Section 6; failure to do so renders a will invalid and results in intestacy.
Wills Act (s.6) — testamentary formalities — burden on propounder to prove proper execution when suspicious circumstances arise; forgery allegations; witness credibility and non-production of attesting witness; requirement of affirmative proof (documentary/expert) to dispel suspicion.
27 November 2024
Whether statutory penalties under the mining law void cooperative mining contracts and whether a corporation can hold an artisanal licence.
Mines and Minerals Development Act – section 12(1) breach – statutory penalties – effect on contractual enforceability; artisanal mining licence – capacity to hold (citizen/co-operative) – illegality of contract; duty of due diligence.
21 November 2024
Whether the applicant proved paternity to claim intestate succession and whether originating summons should be treated as a writ.
Intestate succession – paternity dispute – originating summons v writ – Order 28 RSC discretion – DNA evidence as conclusive proof of parentage – presumption of parentage – burden of proof in inheritance claims.
20 November 2024
Fixed-term contract expired by effluxion of time; late non-renewal notice breached clause 12.2 but warrants only one month's salary.
Employment law — fixed-term contract expires by effluxion of time — legitimate expectation of renewal requires employer representation or continued employment after expiry — late administrative notice breaches contract clause 12.2 but attracts normal measure of damages (one month's salary).
20 November 2024
Whether the respondent could claim commission before season end and the legal effect of payment into court on costs and interest.
Contract – interpretation of payment clauses – clause 5.2 commission payable only after season; clause 5.1 bi‑weekly invoices based on minimum fee valid; premature claims; payment into court – effect on liability, costs and interest; assessment by Registrar; possessory lien/set‑off issues.
20 November 2024
Purchaser’s payment into agent’s personal account was a red flag; employer not vicariously liable and equitable reliefs denied.
Agency — apparent/ostensible authority; agent acting outside scope of authority; vicarious liability — limits where third party is put on notice; suspicious mode of payment (personal account) as red flag; remedy — refusal of specific performance and vesting order where principal not liable.
20 November 2024
Claim for recovery of land held statute‑barred: accrual on dispossession and no proven concealment to postpone limitation.
Limitation of actions – accrual of cause of action on dispossession – Limitation Act 1939 s.4(3), s.5(1), s.12; section 26 (fraud/concealment) – requirement of reasonable diligence to discover fraud – fraudulent concealment must be pleaded and proved – jurisdiction where action is statute‑barred.
19 November 2024
Assessment of lost-business (special) damages must be evidence‑based, formulaic, and may require expert valuation; erroneous assessments remitted.
Civil procedure – assessment of special damages (lost business profits) – requirement to calculate net monthly profit from financial statements, apply correct loss period, allow for mitigation and avoided costs, and engage expert evidence; appellate interference where wrong principle, misapprehension of facts or manifestly unreasonable award.
19 November 2024
Quantum meruit allowed recovery for services performed at request despite provider being an unregistered architect.
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19 November 2024
Applicant's conduct did not amount to constructive dismissal and the six-month statutory probation limit was not breached.
Employment law – constructive dismissal – employer conduct must amount to fundamental breach; resignation must be prompt. Employment Code Act s27(1),(5) – probationary period limited to six months. Damages – award set aside where foundational dismissal finding unsupported.
19 November 2024
Late application to file answer denied for dilatory conduct; appeal dismissed; costs order set aside.
Industrial relations — extension of time to file an answer — dilatory and inordinate delay — discretion requires justifiable reasons (Chiragben) — party absent at hearing: court may proceed — Industrial Relations Court Rule 44 limits costs awards.
19 November 2024
An employer’s unjustified delay and failure to attend justified proceeding in its absence and dismissal of its appeal.
Industrial relations — failure to file answer — application for leave to file out of time — dilatory conduct — discretion to extend time requires justifiable reasons — court may proceed in absence of party aware of hearing — costs in IRD constrained by Rule 44 (unreasonable delay/misconduct).
19 November 2024
Court dismissed applicant's challenge, affirming lineage primacy and Litunga's customary supervisory installation.
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19 November 2024
Whether arranging collection of goods without possession can found a lien and whether such seizure amounted to trespass and conversion.
Property law — Trespass to goods and conversion — Lien requires actual possession — Burden of proof on claimant to prove quantity/value of goods — Instalment sale and delivery.
19 November 2024
A registered certificate of title stands absent proved procedural irregularity; appellate court will not upset trial findings of fact lightly.
Land law – Certificate of Title – Conclusiveness and cancellation under the Lands and Deeds Registry Act; Recommendations by district council versus Commissioner of Lands; Standards for disturbing trial findings of fact; Possession, eviction and damages for trespass; Evidence assessment in land disputes.
19 November 2024
Non-disclosure of vehicle registration did not vitiate the sale; an award based on an unadmitted witness statement was set aside.
Contract law – sale and specific performance; alleged fraudulent misrepresentation by non-disclosure of asset registration; evidentiary foundation – requirement to lay predicate for documentary/testimonial evidence; special damages – need for particularisation and proof.
19 November 2024
Appeal allowed; judgment set aside in part and remitted for a fresh, balanced accounting before a different registrar.
Agricultural charge – duty to account – adequacy of accounting and supporting vouchers – valuation of assets and crops – Registrar vs Judge jurisdiction – distinction between judgment on assessment and accounting – remittal for balanced accounting.
19 November 2024
Issuing a summons before a formal charge breaches statutory procedure and renders the proceedings a nullity.
Criminal procedure — sections 90(4) & 91(1) CPC — formal charge must be drawn and signed before issuing summons; Judicial review — procedural impropriety; Ultra vires acts; Jurisdiction where leave already granted.
19 November 2024
An application to try a preliminary point on stayability was dismissed because proceedings were stayed pending contempt.
Civil procedure — Order 33 Rule 3 RSC — Preliminary issues — Whether a ruling refusing relief is stayable — Obedience to court orders pending vacation or appeal — Contempt proceedings based on disobedience of an ex parte stay order.
18 November 2024
Appeal dismissed: prolonged absenteeism justified dismissal despite procedural defects; appellant failed to prove pay, reinstatement or expense claims.
Employment law — Police service disciplinary procedure — Absence without leave for 28+ days as prima facie evidence of intention not to return — Procedural irregularity not fatal where offence warrants dismissal — Reinstatement, salary arrears and expenses claims require proof — Appeal court reluctant to interfere with factual findings.
18 November 2024
Appellants acquitted where involuntary confessions, demonstrative evidence and an improperly tendered ballistic report left insufficient proof.
Criminal law — admissibility of confessions and demonstrations — voluntariness — trial within a trial — circumstantial evidence — inadmissible ballistic report tendered by non-author — convictions quashed for lack of proof beyond reasonable doubt.
15 November 2024
An incoherent High Court ruling was set aside and the employment claim dismissed as res judicata; no order as to costs.
Civil procedure — res judicata and abuse of court process — preliminary points of law — necessity for clear, reasoned rulings — appellate determination on the record due to undue delay — costs in employment disputes.
15 November 2024
Failure to hold a trial-within-a-trial is curable absent prejudice; circumstantial evidence upheld murder convictions.
Evidence — leading and voluntariness; trial-within-a-trial; circumstantial evidence and last-seen theory; recovery of exhibits; curable irregularity absent prejudice.
15 November 2024
Conviction for defilement quashed where identity of the accused lacked requisite corroboration despite medical proof of defilement.
Criminal law – Sexual offences – Defilement – Corroboration required of both commission and identity in cases involving young complainants – Medical evidence corroborates commission but not necessarily identity – Opportunity evidence may not suffice as corroboration.
15 November 2024
Conviction quashed and retrial ordered after defective voire dire led to exclusion of child‑witness evidence.
Criminal law – Evidence of child witness – Voire dire – Section 122 Juveniles Act requires sufficient intelligence and understanding of duty to tell truth – Defective voire dire renders child’s sworn evidence void ab initio – Discounting child evidence may necessitate retrial; Provocation defence – cannot be determined if central evidence excluded.
12 November 2024
Appellate court upheld trial judge's discretionary refusal to order security for costs; appeal dismissed with costs.
Civil procedure — Security for costs — Order XL r.71 High Court Rules; Order 23 r.1 RSC — Judicial discretion — Appellate interference limited — Corporate personality and adequacy of assets — Proof of residence (tenancy) — Raising new issues on appeal.
7 November 2024
7 November 2024
An appellate court upheld an interim injunction protecting a disputed plant, finding damages inadequate and the appeal without merit.
Arbitration – interim injunction – application of American Cyanamid test – irreparable harm and inadequacy of damages – prima facie findings on termination permissible at interlocutory stage – merchantability reserved for arbitration.
5 November 2024
A first offender who pleads guilty to causing death by dangerous driving should ordinarily be fined unless recklessness or aggravating factors are shown.
Criminal law – Road Traffic Act s.161(1) – Causing death by dangerous driving – Sentencing – First offender – Plea of guilty – Fine preferred to imprisonment absent recklessness or aggravating factors; requirement for trial court to identify aggravating circumstances when imposing custodial sentence.
4 November 2024
Application to expunge affidavit passages and grant leave to appeal over refusal to allow examination of summoned witnesses in forfeiture proceedings.
Civil procedure — Affidavit evidence — Limits on affidavits (opinion, legal argument, speculation) — Expungement under Order 41 White Book; Forfeiture proceedings — oral evidence vs affidavit procedure — legitimate expectation to call witnesses; Leave to appeal — realistic prospects of success and questions of public importance.
4 November 2024
Cause of action in land disputes accrues when the challenged certificate of title is issued, so limitation must be assessed accordingly.
Limitation of actions – accrual of cause of action – land recovery – time runs when all material facts exist and a defendant can be sued – certificate of title issuance as triggering event – jurisdiction to dismiss on limitation requires clear entitlement.
4 November 2024
High Court lacked jurisdiction to transfer re-entry challenge; such claims must be brought in the Lands Tribunal.
Lands Act s13(3) – certificate of re-entry – exclusive mode of commencement in the Lands Tribunal; High Court Act s13 – equitable jurisdiction; High Court Act s23(1) and High Court Rules Order 19(3)(u) – transfers within the High Court only; jurisdiction – subject-matter jurisdiction essential; forum shopping/abuse of process – discontinuance and recommencement.
1 November 2024
Applicants failed to show a point of law of public importance; leave to appeal and stay were refused.
Appeal — Leave to appeal to Supreme Court — Section 13(3) Court of Appeal Act — Point of law of public importance — Receivership v Insolvency — Scope of third‑party fixed and floating charge — Notice of appointment limiting receiver to movable assets — Stay of execution.
1 November 2024