Court of Appeal of Zambia - 2024 December

18 judgments
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18 judgments
Citation
Judgment date
December 2024
Consent orders are final and only challengeable by fresh action; writs of possession require a possession order and notice to occupants.
Civil procedure – Consent orders – Finality and manner of challenge (fresh action required); Enforcement of judgments – Writ of possession requires underlying possession order and leave of court; Requirement of notice to persons in actual possession before writ issued; Protection of innocent purchasers in possession.
31 December 2024
Whether the applicant may obtain review under Order 39 absent fresh material evidence, rather than appeal the ruling.
Civil procedure – Review under Order 39 High Court Rules – discretionary power – review generally requires discovery of fresh material evidence not discoverable with reasonable diligence – review not to be used as an appeal; Discovery and inspection – procedural requirements when applying to file supplementary documents; Failure to exhibit documents may justify refusal to grant leave to produce them; Review vs appeal – limits to re‑litigation.
31 December 2024
Whether an employee who resigned is entitled to gratuity, pension portability and accrued leave; court ordered payments and pension statements.
Employment law – termination by resignation – interplay of contractual entitlements (pre-2019) and Employment Code (post-2019) – Section 127 Employment Code; gratuity under Section 73 – pension portability and employer duty to provide statements (Pension Scheme Regulation Act s18) – accrued leave pay – burden of proof for salary arrears – interest and costs.
30 December 2024
Applicant failed to show special circumstances and realistic, irreparable prejudice to justify a stay pending appeal.
Civil procedure — Stay of proceedings pending appeal — applicant must show realistic prospects of success and special/exceptional circumstances; balancing prejudice to parties.
29 December 2024
23 December 2024
Stale theft claims barred by limitation; contractual cap (ZMW 2,500) on employee‑caused losses enforced; appeals dismissed.
Limitation of actions – accrual of cause of action for theft; Contract law – enforceability of limitation/exemption clauses; Liability for employee‑committed theft as contractual negligence; Assessment of quantum limited by contractual cap; Requirement of pleadings and proof for damages and set‑off.
23 December 2024
23 December 2024
Juvenile murder convicts must be sentenced under the law at the offence time—detention during President’s pleasure, not life imprisonment.
Criminal law — Sentencing juvenile offenders convicted of murder — Application of law at time of offence — Section 25(2) Penal Code (pre-2022): detention during President's pleasure — subsequent statutory amendments not applicable retrospectively.
18 December 2024
Applicant convicted of defilement granted bail pending appeal where court found high prospects of success and imposed conditions.
Criminal law - Bail pending appeal - Court of Appeal Act s18(1) - Previewing prospects of success - Criteria from Anuj Kumar Rathi Krishna (likelihood of success, exceptional circumstances, risk of serving sentence) - Defilement conviction - Conditions: K10,000 recognizance, two sureties, fortnightly reporting.
18 December 2024
Flawed trial-within-trial and premature admission of confessions rendered convictions unsafe; appellants acquitted.
Criminal procedure – admissibility of confessions – identification and production procedure – conduct of trial within a trial – prohibition on using statement contents before admissibility – burden of proof.
18 December 2024
A bona fide restructuring that diminishes the need for particular work can lawfully justify redundancy; appeal dismissed.
Employment law — Redundancy — Section 55(1)(b) — restructuring and diminished requirement for particular work; employment pool — lawful consequence of reorganisation; notice periods — contractual terms more favourable than statute (Section 127) prevail; constructive dismissal requires resignation; victimisation claims require evidential support.
17 December 2024
Section 54 severance pay does not apply to dismissed employees and permanent/pensionable employees except in redundancy cases.
Employment law – Severance pay – Interpretation of Section 54 Employment Code Act – Distinction between dismissal and termination – Permanent and pensionable contracts – Redundancy – Measure of damages for unfair dismissal (notice period)
10 December 2024
Possession and active involvement can render the appellant personally liable for a missing vehicle despite not being estate administrator.
Civil law – possession and control – liability for disappearance of property – burden of proof on balance of probabilities – personal liability despite non‑appointment as estate administrator; evidential weight of conduct (inspection, instructions, offers to compensate).
10 December 2024
Payment to the tax authority was not an unequivocal admission; summary judgment was inappropriate and the appeal is dismissed.
Civil procedure — Judgment on admission — Admission must be clear, plain and unequivocal — Payment to tax authority does not necessarily constitute admission — Judicial discretion to refuse summary judgment where liability disputed — VAT liability and reservation of rights.
9 December 2024
A demand performance bond is autonomous and payable on compliance with its terms; alleged fraud must be pleaded and proved to a high standard.
Performance bonds – autonomy of demand guarantees – conditions for payment; Fraud — burden and particularity of proof; Demand timing and statement of breach; Distinctness of bond claims and underlying contractual claims; Unjust enrichment/set-off rejected.
9 December 2024
Court retained jurisdiction despite lapse of one year and allowed substitution of the respondent to the correct legal entity.
Jurisdiction — Industrial and Labour Relations Act — lapse of one year does not automatically terminate court's jurisdiction where Guardall decision has been overruled; Parties — substitution/joinder after judgment — permissible to join or substitute affected parties to avoid multiplicity and ensure justice; Precedent — Citibank v. Suhayl Dudhia reversed Guardall; Procedure — courts have discretion to add or substitute parties where outcome affects them.
9 December 2024
Appeal dismissed: Order 14A properly applied; fraud not proved; action barred as multiplicity/res judicata; costs awarded.
Civil procedure – Order 14A RSC – interlocutory determination disposing of matter without full trial; Fraud vitiating judgments – high onus of proof; Multiplicity of actions/res judicata – relitigation where fraud was previously litigated; Use of criminal proceedings in civil cases – evidential material admissible but conviction outcome not usable as proof; High Court judges – equal jurisdiction; setting aside another judge’s judgment requires established fraud.
9 December 2024
9 December 2024