Court of Appeal of Zambia - 2024 June

39 judgments
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39 judgments
Citation
Judgment date
June 2024
Allotment of unissued insurer shares without members’ approval and paid consideration is void ab initio; appeal dismissed.
Company law – issued versus unissued shares – allotment/subscription of unissued shares – Section 216(1) repealed Companies Act – regulator’s minimum paid‑up capital (SI No.71 of 2015) – requirement for members’ approval and cash consideration – invalid allotment void ab initio – Turquand rule and s.216(5) inapplicable where statutory formalities absent or bad faith – improperly constituted board and void management acts.
28 June 2024
Arbitral award on statutory discrimination set aside because arbitrator exceeded contractual scope and matter was non-arbitrable.
Arbitration — scope of submission — jurisdiction of arbitrator; Arbitrability of statutory discrimination claims (Employment Code s.5); public policy and setting aside arbitral awards; pleadings and terms of reference; award exceeding mandate.
27 June 2024
Composite employee withdrawal notices are permissible, but employers must advise that withdrawal takes effect only after three months; appeal allowed in part.
Labour law – trade union subscription deductions – withdrawal from deduction agreements – validity of composite notices under s.22(2) – employer’s duty to advise on three-month notice; civil procedure – case management and closure for non-attendance.
27 June 2024
Failure to serve a mandatory letter of demand invalidated proceedings against that respondent; only that respondent's claim should be dismissed.
Civil procedure — Originating process and mandatory requirements — Order VI Rule 1(1)(d) High Court Rules — letter of demand — effect of non‑compliance; Order 14A (White Book) — jurisdiction to determine points of law finally; corporate personality — service on one group company not imputed to another; remedy limited to dismissal as against non‑served defendant.
26 June 2024
Court set aside an irregular late review that barred appellant’s witnesses for non-filing of witness statements.
Civil procedure — Interlocutory rulings — Review under Order 39 — Review period and requirement to afford parties hearing; Witness statements — Order XIX (as amended by S.I. No. 58 of 2020) — Mandatory filing vs. court’s discretion to permit testimony; Procedural irregularity — Effect of late, sua sponte alteration of an earlier ruling.
26 June 2024
A written payment-plan signed by the parties estops the appellant from reneging; outstanding terminal benefits award upheld.
Employment law – terminal benefits and payment-plan agreements – estoppel – admissibility of emails and extrinsic evidence to establish a settlement – failure to prove vehicle transfer as full and final settlement or set-off.
26 June 2024
Appeal dismissed: duty and breach proven but dependency unproven; award for loss of expectation of life upheld.
Negligence – statutory duty of care under wildlife legislation – loss of expectation of life – assessment of damages (exchange-rate and precedent considerations) – dependency claims under Fatal Accidents Act – burden and sufficiency of evidence to quantify special damages.
21 June 2024
Recognition by a known witness and bloodied trousers corroborated identification despite absent DNA, appeal dismissed.
Criminal law – Identification of accused – Recognition of known person – Corroboration by circumstantial evidence (blood-stained clothing as odd coincidence) – Absence of DNA does not automatically make conviction unsafe.
21 June 2024
Whether instant mob justice and untested confessions sustain murder convictions or warrant manslaughter substitution.
Criminal law – Confession evidence – trial must enquire into voluntariness before admission; Mob/instant justice – participation in collective assault may ground manslaughter but not necessarily murder absent common purpose; Cumulative assaults and causation – post‑mortem findings and eyewitnesses support liability.
21 June 2024
Leave to commence committal proceedings under Order 52 RSC is mandatory, must be ex parte, and absence of such leave divests the court of jurisdiction.
Civil procedure – Committal for contempt – Order 52 Rule 2 RSC – mandatory ex parte leave – jurisdictional requirement – hearing inter partes unlawful – merits cannot be decided before leave – remittal for fresh ex parte hearing; costs awarded to appellant.
21 June 2024
A provocation defence fails where the alleged provocative act was committed by a third party, not the deceased, so sentence upheld.
Criminal law — Murder — Provocation — Failed provocation may be extenuating — Section 206 Penal Code requires provocative act by the person killed — Ownership of weapon and conduct may rebut provocation claim.
21 June 2024
Appeal dismissed: sufficient evidence of stabbing and malice aforethought; no evidence to sustain provocation or self‑defence.
Criminal law – Murder – malice aforethought (s.204 Penal Code) – evidence of stabbing and post‑mortem findings – provocation and self‑defence require evidential basis – appellate restraint on interfering with reasonable factual findings – extenuating circumstances relate to sentencing.
21 June 2024
Appellate court found a trial judge's mathematical error left K29,000 outstanding and ordered payment before return of the title deed.
Contract/secured loan – forward purchase agreement – withholding of certificate of title; Evidence – proof of payments and attribution to loan officer; Appeal – appellate interference with factual findings where miscalculation/perverse finding; Remedies – order for payment, return of title deed or conveyance; Costs awarded.
21 June 2024
Interpleader resolves ownership of seized goods; alleged forcible entry requires separate proceedings and does not defeat interpleader.
Interpleader proceedings — ownership of goods seized in execution — scope limited to ownership disputes; alleged forcible entry/wrongful execution not determinative in interpleader; separate remedy required for wrongful execution; appellate review of factual findings (perversity/absence of evidence).
20 June 2024
A court lacks jurisdiction to amend commencement mode after finding wrong commencement; successful party entitled to costs.
Civil procedure — Mode of commencement — Originating summons vs writ — Court lacks jurisdiction to amend process after finding wrong commencement — Orders made thereafter invalid — 'Costs follow the event' principle — entitlement to costs where preliminary point succeeds.
20 June 2024
Claims against a bank taken into possession by the Bank of Zambia must follow the Act's liquidation procedures.
Banking and Financial Services Act 2017 – Bank of Zambia possession – liquidation schedule – customer statements – requirement to file claims/objections – jurisdiction of Industrial Relations Division – applicability of John Mutale.
20 June 2024
Court warns against uncritical reliance on handwriting experts but upholds ownership based on undisputed payment and conduct.
Evidence — Expert witnesses (handwriting) — Court's duty to see and assess documentary basis for expert opinion; Proof of title — payment of purchase balance and payment of ground rent as supporting ownership; Fraud/forgery allegations — need to be distinctly pleaded and proved.
20 June 2024
Whether Order 53(9)(1) allows joinder or only hearing of an interested party in judicial review proceedings.
Judicial review — Order 53(9)(1) RSC — hearing v. joinder of interested parties — sufficient interest — originator of complaint — police investigations — procedural fairness — costs to abide outcome.
19 June 2024
Whether disputes protecting registered surface rights must be litigated in the High Court or are mandatorily governed by the Mines Act’s arbitration regime.
Mines and Minerals Development Act (Part IV) — surface rights v. mining rights — jurisdiction of High Court for trespass claims — consent, compensation and arbitration provisions — interlocutory determination under Order 14A.
19 June 2024
Plaintiff may recommence after dismissal for want of prosecution; awarded costs must be taxed promptly and do not bar refiling.
Civil procedure – dismissal for want of prosecution – not a decision on the merits; fresh action permissible. Costs – successful party must tax within prescribed time (Order 62 r 29); failure to tax cannot bar refiling. Stay of proceedings pending payment of costs inappropriate; taxation procedure must be followed. Abuse of process.
19 June 2024
A summary dismissal for no cause of action without reasons or a hearing is irregular and is remitted for fresh hearing.
Civil procedure – striking out pleadings – dismissal for want of cause of action – discretionary summary power to strike out to be used only in plain and obvious cases – requirement to follow Order XIX Rule 3 (HCR) pre‑trial procedures – necessity for reasoned rulings and right to be heard.
19 June 2024
Where rescission and refund claims fall outside Order 12, a default judgment was improperly entered and the matter must be remitted for trial.
Civil procedure – Default judgment – Order 12 High Court Rules – Claims for rescission and refund of deposits not within categories permitting entry of default judgment – Misjoinder of procedure – Remedy is appeal and remittal for trial under Order 12(8) – Setting aside premature where judgment improperly entered.
19 June 2024
Non-parties must be joined before challenging a consent order; unsupported factual findings and premature trials warrant reversal.
Civil procedure — Consent judgments — Only parties (or properly joined non-parties) may challenge consent orders; joinder/fresh-action procedure required; appellate reversal where factual findings (fraud/registry irregularities) are unsupported; interlocutory objections must be determined before trial.
19 June 2024
19 June 2024
Bank not liable where authorised signatories lawfully instructed payments and no written instruction or reasonable grounds required bank to inquire.
Banking law — mandate and agency — privity of contract — Quincecare/Quincecare‑type duty and APP fraud — scope of bank's duty to inquire when payments made by authorised signatories — entitlement to account viewing rights limited to authorised signatories and written instructions.
13 June 2024
Appeal dismissed: ex parte applications properly dismissed for want of prosecution due to appellant's inordinate delay and counsel's failure to follow up.
Civil procedure – dismissal for want of prosecution; ex parte applications – failure to prosecute; service of court directives – inference from circumstances; case management and duty of counsel; principles from Birkett v James applied.
13 June 2024
Dismissal for want of prosecution is not res judicata; fresh action permitted; awarded costs must be taxed and enforced separately.
Civil procedure – dismissal for want of prosecution not a decision on merits – res judicata inapplicable; entitlement to commence fresh action; costs recovery procedure (taxation within three months) – court will not stay fresh proceedings for unpaid taxed costs absent proper enforcement steps.
13 June 2024
Review is limited; fresh material evidence is required to reopen a dismissal for want of prosecution.
Civil procedure — Review under Order 39 Rule 1 — Limited scope; fresh material evidence required — Dismissal for want of prosecution — Consent order expressing intention to settle not a final consent judgment — Case management in commercial list.
13 June 2024
Appeal dismissed: High Court had jurisdiction; Ministry letters not formal decisions; adjournment refusal and lower court findings upheld.
Mining law — jurisdiction under MMDA sections 96–97 — notification v. decision; administrative appeals; powers to cancel/suspend licences; trial court discretion to adjourn; burden of proof on plaintiff.
13 June 2024
An exclusive UAE jurisdiction clause governed the contract; Zambian courts must decline jurisdiction under forum non conveniens.
Private international law – forum non conveniens – exclusive jurisdiction clause – governing law (UAE) – effect of foreign jurisdiction clauses – procedural defects (service address; leave to serve out of jurisdiction) – adequacy of pleading (fraud).
13 June 2024
An exclusive Dubai jurisdiction clause was enforced, holding Zambian courts lacked jurisdiction to hear the contract dispute.
Contract law – exclusive jurisdiction clause – forum non conveniens – governing law (UAE) – enforcement of foreign forum clause – leave to serve out of jurisdiction – procedural defects curable but irrelevant where forum inappropriate.
13 June 2024
A non‑party with sufficient interest may be joined to proceedings even after a consent judgment; fresh action may be inappropriate.
Civil procedure – Joinder after consent judgment – Order 15 Rule 6(2)(b) – Locus standi – When joinder preferable to fresh action.
13 June 2024
Appeal allowed: special damages unproven and contributory negligence re-apportioned 70%/30% (appellant/respondent).
Negligence – road traffic accident – special damages require specific pleading and proof – contributory negligence – apportionment of liability (70%/30%) – assessment by Registrar – interest and costs.
11 June 2024
Civil NCB forfeiture requires statutory notice and proof linking property to crime; criminal cautions demand voluntariness safeguards.
Forfeiture of proceeds of crime — Non-conviction (in rem) forfeiture — FPOCA notice requirements (s30) — Service out of jurisdiction vs statutory notice — Admissibility of warn and caution statements obtained in criminal investigations in civil forfeiture — Voluntariness and probative weight — Two-stage test for tainted property — Standard of proof: balance of probabilities.
11 June 2024
Failure to give statutorily required notice and lack of evidence connecting property to crime invalidated non-conviction forfeiture.
Forfeiture of proceeds of crime — Non-conviction forfeiture — Mandatory notice under s30 — "Tainted property" definition and burden on balance of probabilities — Inadmissibility/insufficiency of intelligence evidence — Improper focus on financial capacity.
11 June 2024
The appellant, as agent and bailee, was liable for stolen cement due to breach of duty; transaction was agency, not credit sale.
:[
7 June 2024
Appeal dismissed where appellant repeatedly defaulted and sought last‑minute adjournment in breach of court rules.
Civil procedure — Dismissal for want of prosecution; striking out vs dismissal; Order 35 r.2 High Court Rules; adjournment applications — Order 33 r.2 (10‑day notice) — viva voce adjournments; inordinate delay, contumelious default; mediation not excuse for last‑minute adjournment.
7 June 2024
Failure to file a memorandum of appearance and defence renders an Order 14A RSC preliminary motion incompetent and voids the resulting Ruling.
Civil procedure — Preliminary points under Order 14A RSC — prerequisite of filing memorandum of appearance and defence — failure renders motion incompetent; Lands and Deeds Registry Act — registration of leases; ex parte interim injunctions — Order 29/1 RSC v Order 27/4 HCR; appellate record requirements (pleadings).
5 June 2024
Appellate court will not overturn trial credibility findings in matrimonial disputes absent perversity, lack of evidence, or misapprehension.
Appeal — appellate review of findings of fact — credibility and demeanour — appellate interference only where findings are perverse, unsupported by relevant evidence, or based on misapprehension of facts — matrimonial causes — unreasonable behaviour and irretrievable breakdown.
3 June 2024