Court of Appeal of Zambia - 2024 May

30 judgments
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30 judgments
Citation
Judgment date
May 2024
Appeal allowed: proceedings were brought against the wrong receiver and fraud was not proved to lift the corporate veil.
Corporate veil – Lifting corporate veil under s.175 Corporate Insolvency Act – Requirement of high standard of proof for fraud – Substituted service – Proceedings instituted against wrong party (change of receiver).
31 May 2024
Court dismissed appeal and upheld order directing State-held funds into Court pending resolution; unapproved consent order ineffective.
Procedural law — payment into Court pending determination; consent orders — require court approval to take effect; State Proceedings Act s.24 — court may restrain payment and direct monies payable by State into Court; right to be heard via affidavits.
31 May 2024
A late-filed defence filed before default judgment may be accepted and amended where the original order was not peremptory and no prejudice arises.
Civil procedure – default judgment and appearance – Order 11 Rule 1(3) – late filing of defence; Procedural orders – peremptory (unless) orders v. directory orders; Amendment of pleadings – leave to amend where no prejudice and no new issues; Judicial discretion – curing technical procedural lapses; Constitution – Article 118(2)(e) administration of justice without undue regard to procedural technicalities.
29 May 2024
Whether a chieftaincy succession dispute can be decided under Order 14A or requires a full trial to resolve intertwined factual and legal issues.
Procedure — Order 14A RSC — suitability for determination on point of law; Customary law — installation and recognition of subordinate chiefs; Interplay of fact and law — where factual disputes are interwoven with legal questions a full trial is required; Constitutional Court authorities preserving traditional recognition powers of the Litunga.
29 May 2024
The Attorney General lacked sufficient interest to be joined as intervenor in an appeal over a bank's immunity and a consent judgment.
Joinder — Attorney General — Amicus Curiae/Intervenor — sufficient interest/locus standi — sovereign immunity under SI No.123 of 1992 and COMESA/TDB charter — consent judgment between private parties — interest of justice — procedural discretion.
29 May 2024
Attorney General's application to be joined as intervenor was refused for lack of sufficient interest and potential prejudice.
Civil procedure – Joinder and intervention – Order 15 RSC – Amicus Curiae vs intervenor – Attorney General’s right to intervene when Crown prerogative or public policy affected; International law – immunity from suit of regional development bank – locus standi and sufficient interest; Consent judgments – challenge by fresh action; Stare decisis – per incuriam argument against Supreme Court precedent (Ventriglia).
29 May 2024
Section 40 IGPA allows private civil damages claims for loss from alleged abuse of dominance despite CCPC penalties.
Competition law – abuse of dominance – civil remedies for loss – Section 40 Interpretation and General Provisions Act preserves civil liability despite CCPC penalties – jurisdiction to hear damages claims – cause of action and interlocutory dismissal.
28 May 2024
Whether Regulation 10A(3) ousts court jurisdiction to challenge the President's cancellation of an officer's commission.
Defence Act — Regulation 10A(2)-(3) — ouster clause — 'proceedings' includes judicial proceedings — presidential cancellation of commission final — jurisdiction ousted — statutory interpretation — accrued rights distinguished.
15 May 2024
Whether incorporated trust pleadings disclose tortious causes of action and whether omission of "Registered Trustees" justified striking out.
Civil procedure – strike out – cause of action – tortious claims for forcible eviction and damages; Trusts – Land (Perpetual Succession) Act – incorporated trust (Registered Trustees) can sue and be sued; Abuse of process – multiplicity of actions and nexus with earlier trusteeship dispute.
15 May 2024
Court erred in dismissing action for want of prosecution instead of striking it out when adjournment was refused.
Civil procedure — Dismissal for want of prosecution — Where plaintiff absent but represented, proper course is striking out from active cause list with liberty to restore — Adjournment applications require compelling evidence — Court-driven case management and repeated mediation referrals relevant to attribution of delay — Review of judgment requires fresh evidence not previously available.
15 May 2024
Joinder affirmed: a Certificate of Title showing a prima facie interest suffices at joinder; conflicting survey or sale issues are for trial.
Civil procedure – Joinder of parties (Order 14 r.5 HCR) – Locus standi – Certificate of title as prima facie proof of interest – Preventing multiplicity of actions – Interlocutory relief versus trial of disputed title and contract issues.
15 May 2024
Non-execution of a conditional equity agreement was not a breach; employer complied with repatriation by providing an unused ticket.
Employment law – equity participation clause – separate agreement – conditions precedent – non-execution no breach; Immigration and Deportation Act s28(8) – employer repatriation obligation – provision of air ticket – failure to utilise ticket – evidential burden; appellate review – setting aside orders unsupported by evidence.
14 May 2024
Levelling execution for unassessed or unawarded contractual interest is irregular when judgment awarded LIBOR interest only.
Civil procedure – execution – writ of fieri facias – irregularity where interest endorsed was not assessed or agreed; Affidavit in reply – no leave required to file; Interest on judgment – judgment on admission awarded LIBOR not contractual interest; party cannot unilaterally compute and levy execution for unassessed interest.
14 May 2024
14 May 2024
Application to extend time to appeal dismissed because leave to appeal was not obtained, depriving the Court of jurisdiction.
Civil procedure – Appeal procedure – Leave to appeal refused by High Court – Applicant must apply for leave to appeal to single Judge of Court of Appeal – Extension of time to appeal cannot be granted in absence of leave – Jurisdictional defect.
13 May 2024
Correction under the slip rule is limited to clerical slips and must be sought from the judge who gave the original judgment.
Civil procedure — Correction of judgment (Order 20, Rule 11 RSC) — Slip rule limited to clerical mistakes or accidental omissions — Application for correction should be made to the judge who pronounced the judgment — Res judicata and functus officio limit post‑judgment corrections — Delay and belated applications may constitute abuse of process.
10 May 2024
Judgment on admission set aside: admissions were not clear or unequivocal, matter remitted for trial.
Civil procedure – judgment on admission; admissions must be clear, unequivocal and unambiguous – village banking groups versus corporate promoter – withdrawal of admission – amendment of pleadings – remittal for trial.
10 May 2024
A shareholder cannot be joined over company property without demonstrating a legal interest likely to be affected by the proceedings.
Joinder — Order 14/5(1) HCR — requirement to claim a share or interest and likelihood of being affected; Company law — separate legal personality (Salomon) — shareholders have no proprietary interest in company property; Charging order — procedural challenge not raised below.
9 May 2024
Appeal dismissed: smuggling conviction upheld where financial gain and corroboration proven by documents, admissions and immigration evidence.
Anti‑Human Trafficking Act – smuggling persons – elements require procurement of illegal entry for financial/material gain; corroboration of interested witnesses – possession of forged travel documents and absence of immigration entries as corroboration; accomplice/associated persons – inferences from admissions and conduct; sentencing – mandatory minimum custodial term.
8 May 2024
Whether arbitration and Belgian forum clauses in a marine policy oust Zambian jurisdiction and the effect of insurance statute repeal.
Arbitration clause – construction and effect of mandatory arbitration; forum clause – choice of Belgium and Belgian law; Article 7.3 (assured’s election of court proceedings) – effect and limits; insurance statute (s.120 1997 / s.166 2021) – commencement and retrospective application; contracts in contravention of statute – penalty versus voidness; forum non conveniens and relevance of fraud allegations to jurisdiction.
3 May 2024
Cause of action accrued on acquittal; absence of notice did not postpone limitation period under Limitation Act.
Limitation of actions – Malicious prosecution and false imprisonment – cause of action accrues on date of acquittal – absence of notice of acquittal not fatal to commencing action – Limitation Act 1939 s.26 (postponement for fraud) considered but not shown to apply.
3 May 2024
Appellant’s failure to verify leave for late filings justified dismissal of the objection and costs against the appellant.
Civil procedure — Preliminary objection to witness statement — High Court (Amendment) Rules, Order 30A Rule 3A(3) — requirement to file affidavit in opposition — leave to file documents out of time — duty to check registry for ex parte leave — costs for causing delay and wasting court time.
3 May 2024
Court set aside order piercing the corporate veil for lack of probative evidence; refusal of security for costs upheld.
Company law — Corporate personality — Piercing the corporate veil — Section 175 Corporate Insolvency Act — concealment/evasion/fraud and absence of conventional remedies required — courts must require probative evidence before lifting veil; Security for costs — discretionary, assessed on all circumstances.
3 May 2024
Court set aside dismissal of rights-based claims and remitted matter for hearing due to denial of a fair opportunity to be heard.
Constitutional law – mode of commencement – Article 28 and Protection of Fundamental Rights Rules – Order 14A RSC – preliminary issues vs full trial – procedural fairness – sua sponte jurisdiction to raise mode of commencement – remittal for directions.
3 May 2024
Delay of 1 year+ held inordinate; ex curia talks and Labour Office engagement do not toll time.
Industrial and labour relations — Leave to file complaint out of time — Inordinate delay — Ex curia settlement negotiations do not stop time — Exhaustion of administrative channels means internal employer procedures — Costs under Rule 44 — Award set aside.
2 May 2024
Whether a bank is liable for unauthorized mobile-banking withdrawals where a former director’s phone remained linked to the company account.
Banking law — Mobile/cell-phone banking — Mandate and authority — Liability for unauthorized withdrawals — Third-party indemnity — Appellate review of findings of fact — Due diligence in corporate acquisitions.
2 May 2024
Conviction of a juvenile without parent/guardian present is null; delayed confirmation of reformatory orders may justify substitution with probation.
Juvenile law – Parent/guardian attendance mandatory under s127 – absence renders proceedings a nullity; Juvenile detention – s94 requires conveyance to receiving centre pending confirmation; Delay in confirmation and custody conditions warrant resentencing; Credit for time served may make retrial inappropriate; Substitution with probation under Probation of Offenders Act.
2 May 2024
2 May 2024
Whether the High Court General Division has jurisdiction over redundancy-payment disputes versus exclusive Industrial Relations Division jurisdiction.
'Jurisdiction' – High Court (General Division) retains jurisdiction over pure master-and-servant employment disputes;Industrial Relations Division – exclusive jurisdiction over collective disputes and interpretation of collective/recognition agreements under s.85(9);Employment law – interpretation of Employment Code ss.54 and 55 may be heard in General Division when arising from individual redundancy claims;Procedure – dismissal for want of jurisdiction where General Division competent was erroneous;Costs – general rule costs follow the event, but appellate discretion to make costs abide trial outcome.
2 May 2024
Attempted murder requires proof of actual intent to kill; malice aforethought may be proved by knowledge the act would probably cause death.
Criminal law — Murder: circumstantial evidence — malice aforethought under s.204(b) (knowledge that act will probably cause death) — Attempted murder: requires proof of actual intent to kill, not mere inference — Substitution to maliciously administering poison (s.231) where intent to kill unproven.
2 May 2024