Court of Appeal of Zambia

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2,111 judgments
May 2025
A sale of an exploration licence with express contractual discretion cannot be converted into a joint venture or be limited by an implied reasonable-time term.
  • Contract law — characterization of transaction: sale v joint venture; implied terms — necessity, business efficacy and obviousness tests; contractual discretion — scope, good faith and limits; Net Smelter Return royalty entitlement contingent on commencement of mining; time of the essence — when express discretion exists; burden and particulars required to establish fraud in licence alteration.
9 May 2025
Joinder of an amicus curiae after judgment is improper without a pending appeal; amicus participation is governed by common law rather than party-joinder rules.
  • Civil procedure — joinder of parties — amicus curiae — functus officio — joinder after judgment requires pending appeal or review — amici are not parties and should not be joined under party-joinder rules.
9 May 2025
April 2025
Court refused to dismiss appeal where transcript-related delay was outside appellants' control and they acted diligently.
  • Civil procedure — dismissal for want of prosecution (Order X, Rule 7) — discretion to dismiss — delay due to procurement of transcript — inordinate and inexcusable delay — requirement of prejudice or contumelious conduct.
29 April 2025
Court confirmed interim injunction to preserve status quo in land-title dispute and refused admission of fresh evidence.
  • Civil procedure — Interim injunction pending appeal; preservation of status quo; admission of further evidence on appeal (Order 59 RSC; Ladd v Marshall); American Cyanamid principles; competing certificates of title in land dispute.
25 April 2025
Encroachment claim by a registered proprietor was not time-barred, but the registered caveat exceeded the appellant's proprietary interest.
  • Land law — Encroachment by usage — Accrual of cause of action on subdivision — Statute of Limitations and registered title — Caveat scope and proprietary interest — Survey diagrams and title evidence.
25 April 2025
Alleged out‑of‑court settlement did not bind parties or nullify taxation of costs; application dismissed as vexatious.
  • Settlement agreements — whether correspondence and acknowledgement constitute acceptance; Taxation of costs — whether nullified by alleged out‑of‑court settlement; Civil procedure — applicability of Order 14A RSC, Order 8 CAR and Order 33 RSC; Abuse of process — vexatious litigation; Functus officio doctrine.
24 April 2025
Application for leave to appeal dismissed: applicants failed to show public importance, prospects of success, or compelling reasons.
  • Court of Appeal — leave to appeal to Supreme Court — Section 13(3) Court of Appeal Act — criteria: point of law of public importance, reasonable prospects of success, compelling reasons; Arbitration — Arbitration Act s.17(2)(b) — subject‑matter not arbitrable; Public policy — setting aside arbitral awards; Employment law — arbitrability of unfair discrimination claims under the Employment Code; Limits on arbitral tribunals — reliance on third‑party employment contracts and powers reserved to the court.
16 April 2025
An employer may not invoke a notice clause to evade disciplinary proceedings; courts can look behind termination to protect the respondent.
  • 'Employment law — termination — interplay between contractual notice clause and ongoing disciplinary proceedings; wrongful dismissal where employer abandons disciplinary process.'
15 April 2025
Court distinguishes wrongful and unfair dismissal, upholds finding of employer system failure, sets aside pension award, and declares dismissal unfair.
  • Employment law — wrongful v unfair dismissal — distinction between procedural (wrongful) and substantive (unfair) inquiries; Evidence — probative value of admissions elicited in cross-examination; Employer liability — proximate cause of loss attributable to IT system failure, not employees; Damages — exceptional circumstances may justify awards beyond notice period; Pension entitlement — requires evidentiary proof.
15 April 2025
Court of Appeal lacked jurisdiction to grant stay absent prior application to the lower court; ex-parte stay discharged.
  • Civil procedure — Jurisdiction of Court of Appeal to hear urgent/interlocutory applications — Requirement to first apply to lower court under Order 59 r.14 RSC — Ex-parte stay of execution — Discharge for want of jurisdiction — Enforcement of lower court judgments.
11 April 2025
Incorporation of a company precludes a partnership in the same name; suit against that non-existent firm dismissed.
  • Partnership law — Formation by conduct — Whether an unsigned partnership agreement adopted by conduct can create a firm
  • Company law — Effect of incorporation — Whether incorporation of a company precludes existence of a partnership under the same name
  • Civil procedure — Capacity to sue — Whether an unincorporated firm (non‑legal entity) can be sued in its own name
10 April 2025
Leave to appeal refused: performance alone does not create legitimate expectation to renew a fixed‑term contract.
  • Civil procedure — Leave to appeal to Supreme Court under s.13 CAA — requirement of point of law of public importance and real prospects of success; Employment law — legitimate expectation of renewal of fixed-term contract — assurance or employer conduct required; performance alone insufficient.
10 April 2025
Application to set aside taxation adjournment dismissed as filed out of time without leave, depriving Court of jurisdiction.
  • Civil procedure — Preliminary objection — Jurisdiction to hear applications filed out of time; Reasonable time where rules silent — 14 days; Extension of time — Order 13 rule 3(2) — leave required after expiry; Procedural form requirements may be jurisdictional but were not decided.
4 April 2025
Applicants failed to show realistic prospects of success; leave to appeal the derivative-action ruling was denied with costs.
  • Companies law — Derivative actions — Leave to commence/appeal — Companies Act s331(3) — Prospects of success at interlocutory stage — Review of interlocutory rulings — Procedural fairness (consideration of opposing documents) — Multiplicity of actions and costs.
1 April 2025
March 2025
Court upheld entitlement to unpaid allowances despite board non-determination; appellate court refused to disturb factual findings.
  • Employment law — allowances — interpretation of 'shall' and 'as determined by the Board' — accrued contractual benefits — facilitative imprest versus remunerative allowance — alleged transcription error in conditions of service — contra proferentum — appellate interference with factual findings — s.85A(d) ILRA discretionary awards.
31 March 2025
A purposive reading of Order 10 Rule 9(2) permits combined law-and-fact grounds if clearly stated; preliminary objection dismissed.
  • Civil procedure — Appeals — Order 10 Rule 9(2) CAR — Grounds of appeal must be concise and specify points of law or fact — Purposive interpretation permits combined law-and-fact grounds where clear — Preliminary objection dismissed where grounds disclose issues and contain no argument or narrative; ex parte leave not set aside confers jurisdiction.
27 March 2025
Failure to exhaust internal disciplinary appeals does not automatically bar a court claim; non-exhaustion affects credibility, not jurisdiction.
  • Industrial & Labour Relations Act s85(3) — jurisdiction — exhaustion of internal administrative/grievance channels — failure to exhaust does not automatically extinguish cause of action; internal appeal optional where policy uses "should"; non-exhaustion affects credibility/merits, not jurisdiction.
26 March 2025
Applicant must prove tainted property on a balance of probabilities; suspicion of foreign wrongdoing is insufficient.
  • Forfeiture — civil (non‑conviction) forfeiture — burden of proof on public prosecutor — 'tainted property' must be proved on balance of probabilities — mere reasonable suspicion or unparticularised foreign investigations insufficient — Section 29, 30(b), 31 and 34 Forfeiture of Proceeds of Crime Act.
24 March 2025
Court granted extension to file record and heads, holding late filing affected discretion not jurisdiction.
  • Civil procedure — Extension of time — Order 13 Rule 3 CARs — Jurisdiction vs discretion — Late application within 21-day cushion — Transcript delay as justifiable cause — No inordinate delay (Birkett v James).
11 March 2025
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