Court of Appeal of Zambia - 2024

348 judgments
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348 judgments
Citation
Judgment date
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
October 2024
Court allowed the applicant's appeal because the High Court determined sua sponte legal issues without hearing the parties.
Constitutional reference (Art.128(2)) — sua sponte determination — inherent jurisdiction vs Order 14A — audi alteram partem — locus standi — petition formalities.
31 October 2024
The applicant's dilatory conduct and failure to show sufficient cause justified refusal to set aside judgment obtained in his absence.
Civil procedure – setting aside judgment obtained in absence – Order 35 rules 4 & 5 – "sufficient cause" – proof of service – case management and unless orders – finality of litigation – litigant dilatoriness.
31 October 2024
A garnishee order binds subsequent deposits into the same account: accruing credits may satisfy the outstanding judgment debt.
Garnishee proceedings — third‑party debt order — Order 49 Rule 1 (White Book) — "debt due or accruing" — attachment of subsequent credits to the same account — Heppenstall distinguished — chose in action frozen for enforcement of judgment debt.
31 October 2024
Deposit of title deeds created an equitable mortgage; assigned receivables were not the sole security—appeal dismissed.
Revolving invoice discounting facility — receivables as pledged source of repayment but not sole security — surrender/deposit of title deeds creates third‑party equitable mortgage — equity of redemption preserved — frustration not established.
31 October 2024
Specific performance and rescission are mutually exclusive; inconsistent remedies must be pleaded alternatively and the record remitted for rehearing.
Specific performance; rescission of contract; inconsistent remedies must be pleaded in the alternative (Order XVIII Rule 15); trial court's election of remedy; defective pleadings; remission for fresh hearing.
31 October 2024
Appeal dismissed for non‑compliance with record‑of‑appeal rules where appellant delayed seeking amendment.
Appeal procedure — defective record of appeal — non‑compliance with Order 10 Rule 9(5)(c) and 9(7) — jurisdictional preliminary objection — discretion to allow amendment — delay fatal to relief.
31 October 2024
Appellant must refund ZMW 1,220,843 taken to pay ZRA; fraud claims dismissed; costs awarded to the respondent.
Commercial law – recovery of funds paid for release of impounded goods – payment intended for tax to revenue authority versus consultancy fee – misappropriation/repayment – proof required for fraudulent misrepresentation – costs follow the event; appellate restraint on interfering with trial judge's discretion.
31 October 2024
The appellant’s diary error was not a sufficient excuse; the application to set aside was time‑barred and appeal dismissed.
Civil procedure — Setting aside judgment obtained in absence of a party — Order XXXV High Court Rules and Order XXXV Rules of the Supreme Court — seven‑day time limit for application to set aside — adequacy of explanation for non‑attendance — discretion to reopen trial — costs as alternative remedy.
31 October 2024
Whether a tribunal abused its discretion in ordering subpoenas absent detailed findings of disputed facts.
Procedure — Capital Markets Tribunal — Power to subpoena witnesses and compel documents — Applicant must show contested factual issues and good reasons — Appellate review by abuse-of-discretion standard — Extempore rulings need not recite full argument if reason for decision is discernable.
31 October 2024
The appellant's contingency-fee agreement contingent on litigation recovery was illegal and unenforceable under Rule 8.
Legal practitioners — Contingency fees — Definition and prohibition under Rule 8 of the Legal Practitioners Practice Rules — Debt-collection agreements contingent on recovery unenforceable when recovery achieved through litigation — Distinction between contentious and non-contentious business — Conveyancing and Non-Contentious Matters (Costs) Order exception requires express post-litigation agreement.
30 October 2024
Part performance and documentary memoranda can satisfy the Statute of Frauds for a land sale; vendor cannot unilaterally revise price.
Property law – Sale of land – Statute of Frauds (Section 4) – sufficiency of memorandum and part performance; change of relationship from landlord/tenant to vendor/purchaser; vendor’s attempted unilateral price increase and demand for rent; time not of the essence in open-ended sale agreements.
30 October 2024
Return or replacement of the sold decanter was a condition precedent to payment; appeal dismissed.
Contract/sale of shares – subject-matter (decanter) as integral asset – condition precedent to payment – interpretation of court judgments – inherent jurisdiction to clarify orders – writ of fieri facias and stay of execution.
30 October 2024
Court of Appeal set aside dismissal for want of prosecution and remitted case for trial, finding adjournment justified.
Civil procedure — dismissal for want of prosecution — adjournment — inherent jurisdiction — inordinate delay vs. excusable absence — appellate interference with trial court's discretion — matter restored and remitted for trial.
30 October 2024
Appellant lacked standing to challenge sale under separate charging-order proceedings; appellate court affirmed trial findings and dismissed appeal.
Civil procedure – charging orders and orders for sale – locus to challenge orders granted in separate proceedings – appellate deference to trial findings; property law – bona fide purchaser for value without notice; administrative/contractual claims – entitlement of sitting tenant to purchase; execution by charging order – procedural requirements and effect.
29 October 2024
Appeal allowed: Registrar miscalculated damages; correct judgment debt ZMW 790,023.24 with post-judgment interest at 9.5%.
Civil appeal — assessment of damages — misapprehension of facts by Registrar — correct measure of loss is actual outlay less payments received — interest at average short-term deposit rate for assessment period; post-judgment interest at 9.5% per annum.
23 October 2024
The appellant's challenges to identification and circumstantial evidence failed; conviction and death sentence upheld.
Criminal law – identification evidence – reliability of relative witness; corroboration not always required if danger of false implication excluded. Criminal law – circumstantial evidence – odd coincidences can produce only one reasonable inference of guilt. Criminal procedure – evaluation of alibi and investigative omissions in safety of conviction
17 October 2024
Relative's credible identification plus compelling circumstantial evidence upheld the murder conviction and death sentence.
Criminal law – Murder; Identification by relative witness – admissibility and need for corroboration; Circumstantial evidence – odd coincidences and last-seen principle; Safety of conviction; Appeal dismissed.
17 October 2024
Appellant's murder conviction upheld: relative's identification and circumstantial 'odd coincidences' established guilt as the only reasonable inference.
Criminal law — Identification by close relative — Corroboration of witness with alleged interest — Circumstantial evidence — 'last seen' and 'odd coincidences' doctrine.
17 October 2024
The appellant's appeal dismissed; conviction and death sentence upheld on reliable single identifying witness evidence.
Criminal law – murder; single identifying witness; identification at night; danger of mistaken identity; alibi evidence; appellate review of credibility.
17 October 2024
A caveat requires proof of an enforceable legal or equitable interest; absent such proof, it must be removed and statutory liquidation remedies followed.
Lands and Deeds Registry Act s76—caveatable interest; requirement of legal/equitable interest; absence of mortgage/assignment; promissory estoppel inapplicable; liquidation—statutory remedies under Banking and Financial Services Act.
10 October 2024
Respondent failed to prove the identity of plots; cancellation of the appellant's certificate of title was set aside.
Land law – identity of land – proof of identity of parcel (Plot FS-3/F53 v Stand No. 10959) – burden of proof on claimant; Certificate of title – cancellation only on proven fraud or impropriety and proper evidence; Pleadings – relief must be supported by pleaded case; Appellate interference with trial findings of fact.
10 October 2024
Hearing an appeal without proof of service breached natural justice; appeal allowed and matter remitted to the High Court.
Civil procedure – Service of process – High Court Rules Order 10 Rule 3 – requirement for acknowledgment or affidavit of service where default may lead to final judgment – right to be heard/natural justice – hearing in absence without proof of service vitiates decision – matter remitted for rehearing.
9 October 2024
Leave granted because non‑conviction forfeiture issues raise points of law of public importance.
Non‑conviction asset forfeiture — admissibility of evidence from criminal investigations in civil forfeiture — burden of proof under s33 FPOCA — individual culpability — leave to appeal under s13.
7 October 2024
Whether a High Court tort claim is an abuse of process when a related labour claim is pending before the Industrial Relations Court.
Civil procedure — multiplicity of actions and abuse of process; distinguishing labour (constructive dismissal) and tort claims; jurisdiction of Industrial Relations Court; access to justice (Article 118) — striking out as extinguishing remedy; remittal for trial.
7 October 2024
A Certificate of Title may be cancelled if procured in breach of prescribed allocation procedures; unsigned offer letters and unproved revocation allegations fail.
Land law – Circular No. 1 of 1985 – procedure for allocations and council recommendations; Certificate of Title – conclusive evidence but subject to cancellation for fraud or procedural impropriety; validity/authentication of offer letters; judicial notice and burden of proof; appellate interference with trial factual findings.
3 October 2024
Court upheld cancellation of a title obtained without following statutory allocation procedures; unsigned offer letter unauthenticated.
Lands — Certificate of Title — Cancellation for procedural impropriety — Circular No. 1 of 1985 — Offer letters and authentication — Judicial notice of administrative revocation — Proof of payment and employee concessions.
3 October 2024
Damages for pain and anguish require specific pleading and proof; employer must remit payroll loan deductions or repay employees.
Employment law – redundancy – payroll loan deductions – employer's obligation to remit deductions or repay employees; damages for pain and anguish – must be specifically pleaded and proved; appellate review – abandoned grounds deemed abandoned for lack of argument.
3 October 2024
Allegations of forgery require clear pleading and higher proof; respondent proved contract and entitlement to specific performance.
Contract law – specific performance – remedy available where respondent proved contract and payments.
2 October 2024
Employer must remit or return payroll-deducted loan monies; damages for mental anguish require specific pleading and proof.
Employment law – redundancy – payroll deductions for loan repayments – employer's withholding and non-remittance; Civil procedure – pleading and proof – damages for pain and anguish must be specifically pleaded and proven; Remedies – restitution to employees where third-party creditor is not party to proceedings.
2 October 2024
High Court judgment set aside for failing to state adequate reasons; matter remitted for rehearing before a different judge.
Judgment-writing standards — requirement to state concise facts, issues, findings and reasons; Failure to reveal court’s reasoning — judgment set aside; Remittal for re‑hearing before different judge; Ambiguity in orders and unenforceable decisions; Costs to abide outcome of rehearing.
2 October 2024
Appellant failed to prove entitlement to additional responsibility allowance; appeal dismissed and costs awarded to respondent.
Employment law – Additional responsibility allowance – Requirement of written communication to prove formal appointment to additional duties; proof of entitlement; calculation of terminal benefits; appellate review of factual findings; costs follow the event.
2 October 2024
Court raised jurisdiction sua sponte and set aside lower court judgment because Local Court lacked authority to appoint the administrator.
Civil procedure – jurisdiction – court may raise jurisdiction suo motu – Intestate Succession Act s.43 limits Local Court jurisdiction to estates ≤ K50 – appointment of administrator by Local Court exceeding limit is void – transactions by an unauthorized administrator invalid – judgments without jurisdiction are null and void.
2 October 2024
September 2024
Majority denied leave and stay, holding registration defects curable under the Lands and Deeds Registry Act; dissent would grant leave.
Court of Appeal — leave to appeal (s.13 Court of Appeal Act) — Lands and Deeds Registry Act (s.5, s.6) — registration of letters of administration — whether non-registration curable by court — extension of time for registration — stay of execution — execution already effected — majority refusal, dissent granting leave.
30 September 2024
The applicant's refusal to transfer after corporate restructuring did not amount to redundancy or constructive dismissal.
Employment law – corporate restructuring and acquisition – transfer of rights/obligations; redundancy – when redundancy arises; constructive dismissal – test for breach of fundamental term; contractual interpretation – 'salary review' not inherently an increase; contra proferentem inapplicable where clause clear.
30 September 2024
18 September 2024
18 September 2024
18 September 2024
Appellant entitled to contractual and statutory accrued service benefits; costs not awarded absent misconduct under Rule 44(1).
Employment law – accrued service benefits and severance pay – applicability of Employment Code Act s.54(1)(c) from date of enactment; contracts providing more favourable terms prevail (s.127); Industrial Relations Court Rules – Rule 44(1) limits awards of costs to cases of unreasonable, improper or vexatious conduct.
18 September 2024
17 September 2024
An appeal was dismissed because a late application for extension of time rendered the extension order a nullity, depriving the court of jurisdiction.
Civil procedure — extension of time — jurisdiction — late application renders extension order a nullity — Court of Appeal lacks jurisdiction — appeal dismissed.
16 September 2024
Misjoinder upheld where cybersecurity regulator lacked investigatory mandate and no cause of action was disclosed.
Administrative law – judicial review – misjoinder – necessity to disclose a decision or omission – Cyber Security and Cyber Crimes Act – scope of regulator’s mandate – mandamus – costs.
12 September 2024
Default judgment set aside where claims against the defaulting defendant were inseparable from claims against other defendants.
Civil procedure – Default judgment – Multi-defendant actions – Where claims against defaulting defendant cannot be dealt with separately, default judgment should not be entered pending determination of liability against other defendants – Setting aside default judgment: defence on merits and promptness but also avoidance of inconsistent judgments.
10 September 2024
Writs for service out of jurisdiction must be accompanied by a statement of claim; Registrar’s decisions require appeal under Companies Act.
Civil procedure — service out of jurisdiction — Order X R16 HCR — Order 6 R1 (SI 58/2020) requires statement of claim with writ — mode of commencement — s341 Companies Act — appeal from Registrar — costs discretion.
9 September 2024
Court partially upheld property division, excluded unproven borehole and ordered expert valuation of vehicle; cattle award affirmed.
Matrimonial property division — proof of acquisition during marriage — burden on party alleging asset is matrimonial — appellate restraint on factual findings — valuation and depreciation of assets — appellate judge must not assume valuer's role; expert valuation required — polygamy considered in apportionment.
4 September 2024
4 September 2024