Court of Appeal of Zambia - 2025 February

41 judgments
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Results. 41 judgments found.

41 judgments
February 2025
Vesting order set aside where respondents failed to prove constructive trust or produce documents divesting the registered owner's title.
  • Land law — Vesting orders; requirement of documentary basis for vesting under High Court Act; constructive trust — evidentiary burden; certificate of title protected by section 33 (conclusive evidence of ownership); appellate interference where trial findings are perverse or unsupported by evidence.
27 February 2025
A judgment was set aside because the court failed to consider duly filed heads of argument due to a registry error.
  • Court of Appeal procedure — discretion under Court of Appeal Rules to proceed on filed processes — notice of hearing — right to be heard via filed heads of argument — registry administrative error — judgment set aside and rehearing ordered.
27 February 2025
Omission of documents from a record of appeal does not mandate dismissal; respondent must prove materiality and the court may allow supplementation.
  • Civil procedure — Record of Appeal — omission of documents — Order 10 r 9(5)(h) CARs — materiality of evidence — burden on respondent to prove prejudice — discretionary remedy; supplementary record allowed.
27 February 2025
Appellants were not innocent purchasers; subdivisions created unlawfully within respondent's land rendered titles void ab initio.
  • Property law — bona fide purchaser for value without notice — constructive notice and due diligence; Land law — unlawful creation of subdivisions within titled land; Public Roads Act — road reserve and prohibition of development; Invalidity of titles obtained from void subdivisions; Negligence of land allocation authorities and indemnity.
26 February 2025
An application for extension of time was dismissed for failure to obtain leave to file out of time and ignorance of the Rules.
  • Civil procedure — extension of time — Order XIII Rule 3(1)–(3) Court of Appeal Rules — requirement to file within 21 days or obtain leave to file out of time — sub‑rule (3) read with sub‑rule (2) — ignorance of law not a defence — incompetence of application where no leave to file out of time shown.
26 February 2025
Appellant's account did not create reasonable doubt and diminished responsibility lacked medical support; appeal dismissed.
  • Criminal law — Murder — Circumstantial evidence and admissions; burden of proof and 'reasonably possible' defence; diminished responsibility (s.12A Criminal Procedure Code) — requirement of abnormality of mind and medical evidence; onus on accused to adduce and call psychiatrist.
26 February 2025
Diminished responsibility requires medical evidence; epilepsy here did not establish abnormality of mind, appeal dismissed.
  • Criminal law — Murder — Diminished responsibility (s.12A Penal Code) — Requirement of abnormality of mind supported by medical evidence — Epilepsy as neurological condition, not disease of the mind — Onus on accused to prove unsoundness of mind.
26 February 2025
Circumstantial evidence—utterances, recovered syringe, and toxicology—was sufficiently cogent to uphold the murder conviction; appeal dismissed.
  • Criminal law — Circumstantial evidence — Cogency required to permit only inference of guilt; credibility and corroboration of related witnesses; recovery of syringe and toxicology as corroborative circumstantial proof.
26 February 2025
Whether stepchildren count as "children" under the Intestate Succession Act or only as dependants without formal adoption.
  • Intestate succession — definition of "child" — "adopted child" requires formal legal adoption; stepchildren not automatic heirs — dependants entitled to 10% under s.5(d) — estate to be sold and proceeds distributed under ss.5 and 6.
26 February 2025
Seizure under a regularly issued execution of goods in a debtor’s possession is not wrongful; interpleader is the remedy.
  • Execution law — writ of fieri facias — seizure of third‑party goods in possession of judgment debtor — interpleader (Order XLI rules 53–56) as remedy — defamation claims fail without particularised pleadings.
26 February 2025
Whether voluntary intoxication negated mens rea or amounted to mitigation in a murder conviction.
  • Criminal law — Intoxication under Section 13 Penal Code — voluntary drunkenness not a defence absent incapacity to form intent; intoxication as mitigation must be shown by peculiar facts; mens rea for murder; appellate review of factual findings.
26 February 2025
Whether amended employment-related claims filed with leave outside the 90-day statutory period are statute-barred.
  • Industrial and Labour Relations Act s85(3) — limitation period; pleadings — amendment of pleadings; leave to amend; new cause of action arising from same facts; jurisdiction to hear amended claims; remedy — remittal for trial.
26 February 2025
Continued service after contract expiry did not create renewal; no entitlement to a second vehicle; costs awarded to the appellant.
  • Employment law — fixed-term contracts — clause excluding implied renewal; holding over/continued service entitles only to pro‑rata pay; contract interpretation and sanctity of contract; personal‑to‑holder vehicle entitlement; unjust enrichment; costs follow the event; Employment Code s53(3) (termination on leave) inapplicable where contract expired; plea/pleadings and raising unconscionability on appeal.
26 February 2025
Agency found: 2nd Appellant was agent of 1st Appellant, making 1st Appellant liable for undelivered fertilizer; chairman lacked privity.
  • Agency — implied/apparent agency by conduct and admissions; privity of contract — non-party cannot recover under contract; indoor management (Turquand) rule — outsider entitled to presume internal authority; remedies — market value, interest, general damages and costs.
26 February 2025
A judgment debtor must ordinarily disclose income, assets and liabilities to justify payment by instalments; appeal dismissed.
  • Civil procedure — Order XXXVI r.9 High Court Rules — payment of judgment by instalments — discretion and requirement of sufficient reason — ordinary requirement to disclose income, assets and liabilities — speculative purchase orders insufficient — enforcement of securities.
25 February 2025
Summary dismissal inappropriate where ACC restrictions raise triable issues of frustrated contracts, unpaid interest, and unjust enrichment.
  • Anti‑Corruption Act (s.60) — effect of restriction/seizure notices on bank dealings; Cause of action — meaning and threshold for striking out; Civil procedure — Order 14A/Order 33 RSC summary disposal; Contract frustration and unjust enrichment — triable issues where funds allegedly transferred during restrictions.
25 February 2025
An interlocutory chambers ruling requires leave or renewal before a single judge; appeal was therefore incompetent.
  • Interlocutory procedure — chambers order delivered in open court remains interlocutory — leave to appeal required; stay of proceedings is interlocutory and must be renewed before a single judge — failure to obtain leave or renew renders appeal incompetent.
25 February 2025
Interlocutory injunctions discharged in the High Court must be renewed before a single judge, not appealed; appeal dismissed for irregularity.
  • Procedure — Court of Appeal — Interlocutory orders — Discharge of ex parte interim injunction — Renewal before a single judge, not appeal — Order X Rule 2(1) Court of Appeal Rules — Appeal dismissed for irregularity; costs awarded.
25 February 2025
Leave to appeal refused: proposed grounds raised factual issues, not points of law of public importance.
  • Civil procedure — Leave to appeal to Supreme Court — s.13(3) Court of Appeal Act — point of law of public importance — findings of fact v. point of law — prospects of success — banking law — duty to act on instructions of authorised signatories — internet banking/viewing rights — requirement of evidential basis.
25 February 2025
The appellant's payment plan did not waive mandatory post-judgment interest; appeal dismissed with costs.
  • Judgments Act s.2 — statutory post-judgment interest mandatory; distinction between contractual pre-judgment interest and post-judgment interest; payment plan versus forbearance; evidential weight of correspondence.
25 February 2025
Court upheld injunction preventing further selection or installation of a chief pending trial, though past selection could not be injuncted.
  • Interlocutory injunctions — American Cyanamid principles — preservation of status quo — distinction between past selection and future installation/enthronement — customary succession disputes — irreparable harm and balance of convenience.
24 February 2025
Court granted injunction pending appeal to preserve the subject matter where dismissal left nothing to stay.
  • Injunction pending appeal; stay of execution; where lower court dismisses action awarding no enforceable remedy there is nothing to stay; prospects of success; balance of convenience; preservation of status quo.
24 February 2025
Whether credit notes created a 15% discount and whether trial findings and contractual compound interest should be disturbed on appeal.
  • Civil procedure — appellate review of trial findings — limited grounds for disturbance; burden of proof on balance of probabilities; contract interpretation — credit notes and discounts; contractual compounded interest — enforceability where expressly agreed; assessment of quantum before Registrar.
24 February 2025
Circumstantial evidence and post‑mortem findings upheld the appellant’s murder conviction; failure to call doctor caused no prejudice.
  • Criminal law — circumstantial evidence — threshold for conviction; Post‑mortem evidence — need to call doctor; Accidental fall vs intentional harm; Consciousness of guilt — flight and inconsistent statements; Murder vs manslaughter.
24 February 2025
Appellants' selections were invalid for failing to follow customary succession procedures; Kaunda lineage to supply next chief.
  • Customary succession — chieftainship rotation and lineage eligibility — historical ban/curse on lineage — procedural compliance in selection (representation, queen mothers, meetings) — discretionary use of assessors (s.34 High Court Act) — Cabinet Circular P.A.4/22 of 1972 may apply.
24 February 2025
No oral contract: managing director acted personally and payment went to the foreign supplier; appeal allowed and costs awarded to appellant.
  • Contract law — Oral contracts — requirements of offer, acceptance, intention to create legal relations and consideration; Agency — principal–agent consent; Evidentiary proof — documentary evidence and translation; Burden of proof on balance of probabilities.
24 February 2025
Alleged extra-contractual obligations cannot ground breach where the written contract does not incorporate them.
  • Contract law — written contract governs — extrinsic documents not admissible to vary terms; breach requires proof of contractual obligation
  • Evidence — party alleging loss must plead and prove special damages. Commercial contracts — effluxion of time ends contract; courts must not rewrite agreements
  • Device/configuration — evidence showed phones configured for bank VPN; delays in promotional materials/starter packs did not establish breach
24 February 2025
Recent possession and cogent circumstantial evidence supported convictions for murder and aggravated robbery; appeal dismissed.
  • Criminal law — circumstantial evidence — recent possession doctrine — identification of recovered property — innocent receiver vs perpetrator — murder by ligature (malice aforethought) — aggravated robbery.
21 February 2025
Whether prosecution witnesses were suspect and the appellant's explanation probable; conviction and sentence upheld.
  • Criminal law — Murder — Witness interest and corroboration — Credibility of eyewitnesses — Ballistic corroboration — Improbability of accused's version — Defences of self-defence, provocation and accident unavailable where accused denies firing.
21 February 2025
Circumstantial evidence (child taken into accused’s house, semen observed, medical report) sufficiently established guilt; appeal dismissed.
  • Criminal law — Defilement — Circumstantial evidence — Requirement that inculpatory facts be incompatible with innocence — Single identifying witness — Corroboration where prosecutrix does not testify — Resolution of lingering doubt.
21 February 2025
Appeal allowed: no obligation to release titles; damages award set aside for lack of evidence.
  • Civil procedure; mortgages and security — interpretation of consent settlement orders — obligation to release securities — appellate review of factual findings — proof of damages and requirement to substantiate special/unliquidated loss.
21 February 2025
Failure to serve the record and heads within 14 days without leave renders an appeal incompetent and divests the court of jurisdiction.
  • Civil procedure — Appeal — Mandatory service of Record of Appeal and Heads within 14 days (Order 10 Rule 9(9)) — Non-compliance without leave renders appeal incompetent — Lack of jurisdiction — Appeal dismissed.
20 February 2025
The appellant's murder conviction was upheld because circumstantial evidence left no reasonable inference other than guilt.
  • Criminal law — Murder — Circumstantial evidence — Last seen with victim — Chain of inculpatory facts — Inference must point to nothing else but guilt — Opportunity and evasive conduct as corroboration.
18 February 2025
Child victims' evidence corroborated by medical reports and admissions upheld conviction; 35-year sentence affirmed.
  • Criminal law — Unnatural offences (sodomy) — Child witnesses — Voire dire requirements — Corroboration of identity in sexual offences — Medical evidence and admissions — Sentence appropriateness for multiple child victims.
18 February 2025
Confessions improperly admitted were expunged; two appellants acquitted, first appellant's conviction upheld but death sentence replaced due to age.
  • Criminal law — confession evidence — voluntariness — burden on prosecution to prove beyond reasonable doubt; Trial-within-a-trial — procedural irregularity — prohibition on publishing confessions during inquiry; Civilian witness — cannot narrate confessions given to police; Circumstantial evidence — possession of deceased’s property may sustain conviction; Sentencing — age of offender at time of offence must be established, ocular observation insufficient.
18 February 2025
A proposed success-fee “subject to negotiation” is unenforceable; consultant entitled to market-rate payment for work that produced tax benefits.
  • Contract law — agreement to agree — success-fee clause "subject to negotiation" unconstitutional for uncertainty; contra proferentem; admissibility of extrinsic evidence; attribution of benefits where consultant did foundational work but audit performed by third party; quantum meruit/prevailing market rates; special damages require particularisation and proof.
14 February 2025
Whether a proposed 5% success fee "subject to negotiation" was enforceable and whether appellant's groundwork entitled it to market-rate remuneration.
  • Contract — Agreement to agree — Proposed 5% success fee "subject to negotiation" — unenforceable for uncertainty; Contract interpretation — ambiguity construed contra proferentum against draftsman; Quantum meruit/assessment — appellant performed foundational work for tax benefits; Damages — loss of use requires specific pleading and proof.
14 February 2025
Application for leave to appeal over severance pay entitlement for permanent employees declined for lack of public importance.
  • Employment law — Severance pay (s.54) — fixed-term/long-term contracts vs permanent and pensionable contracts — dismissal under s.51 excludes severance entitlement — leave to appeal (s.13(3) Court of Appeal Act) — public importance and prospects of success.
14 February 2025
Whether the appellant was bound by its agent's unauthorized subdivision and the appropriate remedies, including quantum meruit.
  • Agency law — scope of agent's authority; delegation and sub-agents; construction of written agency agreements; Statute of Frauds and enforceability of MOU/offer letters; remedies — specific performance, damages and quantum meruit; appellate interference with trial findings of fact.
13 February 2025
Court affirmed limited judicial review of arbitral awards; failure to plead facts and show public‑policy breach doomed the appeal.
  • Arbitration law — setting aside arbitral awards — limited judicial review — public policy narrowly construed — Rule 23(2)(c) mandatory affidavit particulars — capacity vs jurisdiction — obiter remarks by tribunal not grounds to set aside award.
13 February 2025
Receiver appointment crystallises floating charge; conditional restructuring was not accepted, allowing mortgage enforcement.
  • Commercial law — Insolvency/Receivership — Effect of receiver appointment on floating charge — Crystallisation and enforcement of security
  • Contract law — Offer and acceptance — Conditional acceptance constitutes counter‑offer; no contract unless conditions met
  • Commercial law — Enforcement of mortgage/security — No moratorium under Corporate Insolvency Act for receivership
3 February 2025