Court of Appeal of Zambia

1,987 judgments
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1,987 judgments
Citation
Judgment date
September 2024
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
Court allowed amendment of divorce petition to five‑year separation as permissible update of factual basis to same statutory cause of action.
Family law — Divorce — Amendment of petition — Whether court may allow amendment to plead five‑year continuous separation accruing after petition — Distinction between amending factual basis within same statutory cause and introducing new cause of action; Rules on amendment (Order 18 R.1, Order III R.2, Matrimonial Causes R.17(2)); Matrimonial Causes Act s.8–9.
4 September 2024
August 2024
An interested party holding competing mining rights must be allowed to apply to be heard in Judicial Review under Order 53 RSC.
Judicial review — procedure — Order 53 RSC applicable to Judicial Review in High Court; Order 53 Rule 9(1) — hearing of a 'proper person' in opposition; joinder vs. permission to be heard; locus standi of interested third party with competing mining rights; scope of stay and status quo pending review.
29 August 2024
Leave under Section 331 is required before a director/shareholder may sue to protect company property; failure renders proceedings a nullity.
Companies Act s.331 – derivative/company actions – leave required for directors/shareholders to sue on behalf of company; receivership – protection of company property; procedural irregularity and abuse of process – nullity of proceedings.
26 August 2024
Mesne profits require wrongful possession; award set aside where no trespass and holding over was not proved.
Mesne profits – requirement of wrongful possession/holding over; burden of proof on claimant; landlord–tenant post-termination occupancy; limits of award where no trespass proven; issues not pleaded cannot be relied on in appeal.
25 August 2024
A non‑customer signatory cannot claim a bank’s Quincecare duty; alleged loss was too remote and strike‑out was proper.
Banking law – negligence – duty of care – Quincecare duty – third‑party signatory – remoteness and foreseeability – strike out for failure to disclose reasonable cause of action.
22 August 2024
Identification by victim’s daughter, uninvestigated alibi, and circumstantial/common-purpose evidence upheld conviction.
Criminal law – identification evidence – witness related to victim – opportunity to observe and bias; Criminal procedure – alibi – police duty to investigate and dereliction of duty; Criminal law – circumstantial evidence – inference of guilt; Criminal law – common purpose liability (Sections 21 & 22 Penal Code); Corroboration by odd coincidence and independent witness evidence.
22 August 2024
A failed provocation defence can constitute extenuating circumstances warranting reduction of a capital sentence.
Criminal law – Murder – Sentencing – Extenuating circumstances – Intoxication: evidential and conduct-based assessment – Provocation: failed defence may still mitigate sentencing – Appeal against sentence – Reduction from death to fixed term.
22 August 2024
A trial judge may not dismiss an inter partes claim sua sponte or refuse relief without reasons; appeal allowed and matter remitted.
Civil procedure – requirement for reasoned judgments and rulings; dismissal sua sponte in inter partes proceedings; cause of action – sufficiency of pleadings; interim injunction applications; right to be heard.
22 August 2024
Whether a financier can be held liable for misrepresentation in a sale to which it was not a party.
Financing agreements v sale contracts – privity of contract; allocation of risk under VAF clauses; liability for misrepresentation by seller; admissibility of unobjected evidence on unpleaded matters; buyer’s duty to inspect; ethical issues in party endorsement and counsel conflicts.
22 August 2024
Appeal dismissed because the relied-upon precedent was overturned by the Supreme Court, leaving the challenge to jurisdiction incompetent.
Civil procedure — jurisdictional lapse for delay in delivering judgment — whether failure to render judgment within one year terminates jurisdiction — Court of Appeal precedent overruled by Supreme Court — effect of Citibank decision on reliance upon Guardall.
22 August 2024
Death of a child during a violent sexual assault justified life imprisonment despite plea and first‑offender status.
Sentencing – Manslaughter – Plea of guilty and first‑offender mitigation – Aggravating factor: death of a child during violent sexual assault – Appellate interference only if sentence wrong in principle or shocks conscience.
22 August 2024
Termination without reasons breaches Section 52; punitive "as if" gratuity clauses unenforceable; excess gratuity and notice in lieu may suffice as damages.
Employment law — wrongful/ unfair termination — Section 52 Employment Code Act — contractual clause paying gratuity "as if" full term punitive and unenforceable — normal measure of damages: notice period/salary in lieu — enhanced damages for mental distress require specific evidence.
22 August 2024
Promotion did not create a new fixed‑term contract; employment ended by effluxion of time and respondent awarded costs.
Contract interpretation – fixed‑term employment – promotion ‘subject to’ clause – no fresh contract on promotion; Changed substratum doctrine – not applicable to create new contract term; Termination by effluxion of time – no notice or payment in lieu required; Legitimate expectation – insufficient evidence; Fringe benefits – end with contract expiry; Costs – discretionary award to successful respondent.
22 August 2024
Covid‑19 quarantine justified absence, but five‑month delay to apply to set aside the judgment was inordinate; appeal dismissed.
Civil procedure – setting aside judgment obtained in absence – Order 35 r.5 High Court Rules – sufficient cause and reasonable time for application; Delay/inordinate delay; COVID‑19 quarantine as excuse for non‑attendance.
22 August 2024
Severance under s54 applies to specified termination/expiry modes, not to dismissal for misconduct; award set aside.
Employment law — Severance pay under s54 Employment Code Act — "Termination" vs "Dismissal" — Severance payable only where contract terminated/expired as prescribed (medical discharge, fixed-duration termination, redundancy, death) — Summarily dismissed employee not entitled to severance pay — Statutory interpretation; expressio unius.
22 August 2024
A shareholder's equity in a company does not, by itself, create a caveatable beneficial interest in company land.
Land law – Caveats – Lands and Deeds Registry Act s76(1) – Beneficial interest – Shareholder/equity contribution does not equate to a caveatable interest in company land; Civil procedure – High Court Rules Order 2 Rule 3 – notice to proceed directed at parties, court may continue proceedings.
22 August 2024
A company lacked locus standi where the loan agreement showed an individual lender and the company’s name appeared later in different handwriting.
Company law – separate legal personality and locus standi; privity of contract – only parties to a contract may sue; documentary evidence and handwriting discrepancies as proof of party status; equitable mortgage evidenced by deposit of Certificate of Title.
22 August 2024
Appellate court upheld trial finding that WhatsApp, conduct and partial performance proved an oral contract and payment, dismissing appeal.
Contract formation — oral agreement evidenced by conduct and WhatsApp correspondence; admissibility and probative value of messages; burden of proof on plaintiff; appellate review of factual findings; award of outstanding payment for undelivered goods.
22 August 2024
Section 54(1)(c) severance/gratuity applies to fixed-duration contracts; dismissed permanent employees cannot claim it under Section 54.
Employment Code Act s54(1)(c) – severance pay/gratuity applies to fixed-duration/long-term contracts; permanent and pensionable contracts are distinct from fixed-term contracts; Section 51 dismissal precludes claim to severance under Section 54; sections 51 and 54 are mutually exclusive.
22 August 2024
The Court upheld the arbitral award as within the arbitration scope and not contrary to public policy.
Arbitration — setting aside award — scope of submission to arbitration; public policy — narrow ground; limited judicial intervention; illegality of one contract does not automatically taint independent contract.
22 August 2024
Court of Appeal held joinder may be ordered post-judgment where justice requires protecting parties' proprietary interests.
Civil procedure — Joinder of parties — Discretionary remedy — Joinder may be ordered post-judgment where in interest of justice — Functus officio not an absolute bar — Protection against deprivation of property without due process.
21 August 2024
Guarantee for US$900,000 enforceable despite pleading mis‑reference and absence of a moneylenders licence; appellant liable after demand.
Contract and suretyship - enforceability of credit guarantee; pleadings and variance - non‑fatal mis‑reference; proof of debt and demand; moneylenders' licence not fatal to principal recovery; Turquand rule — corporate internal authority irrelevant to third parties.
21 August 2024
Fixed-term employment without a renewal clause or clear assurances does not create a legitimate expectation of renewal.
Employment law – Fixed-term contract – Legitimate expectation – Renewal of contract – Performance appraisal – Board resolutions – Effluxion of time – Remedies for non-renewal.
21 August 2024
Dismissal for poor performance was wrongful where systemic SAP procurement failures and procedural irregularities prevailed; 36 months' damages upheld.
Employment law – wrongful and unfair dismissal; procedural compliance – Disciplinary Code v. Poor Performance Procedure/PIP; institutional/systemic failures (SAP) affecting performance; PIP not a disciplinary sanction; measure of damages – departure from contractual notice; appellate limitation on increasing awards without cross-appeal.
21 August 2024
Appeal dismissed: pleadings disclosed a reasonable cause of action and joinder was only suggested, not ordered.
Civil procedure – Order 18 r.19 (White Book) – striking out pleadings – "reasonable cause of action" vs "serious question to be tried" (interim injunctions); joinder of parties – suggestion v formal order; summary disposal reserved for plain and obvious cases.
21 August 2024
Credible identification by known eyewitnesses under moonlight upheld conviction despite an unverified alibi.
Criminal law – Identification evidence – Known witnesses and moonlight recognition – Alibi – Weight of unverified alibi – Appellate deference to trial judge credibility findings – Circumstantial evidence and motive not essential.
20 August 2024
Eyewitness identification and credibility findings upheld; alibi and investigative gaps did not raise reasonable doubt.
Criminal law – Murder; eyewitness identification; alibi; burden of proof beyond reasonable doubt; appellate deference to trial judge’s credibility findings; investigative omissions immaterial where evidence overwhelming.
20 August 2024
A failed defence of provocation may amount to extenuating circumstances warranting reduced sentence for murder.
Criminal law — Murder — Provocation — Failed provocation can constitute extenuating circumstances for sentencing — Trial court misdirection — Sentencing reduction from life to term.
20 August 2024
A first offender under s161 should receive a fine, not imprisonment, absent recklessness or other aggravating factors.
Road Traffic Act s161 – sentencing – fine v imprisonment – first offender – absence of aggravating factors – recklessness required for custodial sentence – appellate intervention where sentence excessive.
20 August 2024
20 August 2024
Murder conviction substituted with manslaughter where fatal injuries occurred during a fight; sentence set at five years.
Criminal law – Circumstantial evidence – Inference of guilt; Criminal law – Homicide: death in course of a fight – Manslaughter v. murder; Causation – necessity of evidential foundation for alternative causes of death.
19 August 2024
Circumstantial and medical evidence excluded suicide hypothesis; conviction for murder and death sentence upheld.
Criminal law - Murder - Circumstantial evidence — must exclude reasonable hypothesis of innocence; postmortem finding of asphyxia by strangulation supports homicide inference; conduct and opportunity of accused as corroborative circumstances.
19 August 2024
Applicant's challenge that he was a juvenile and that his plea was equivocal was dismissed; sentence upheld.
Criminal law – age determination and jurisdiction under Juveniles Act – role of interpretation in age admission – equivocal plea doctrine – materiality of alleged inconsistencies to offence under Anti‑Human Trafficking Act s9(1).
19 August 2024
CCTV recognition corroborated by wallet and unexplained financial transactions upheld convictions for murder and aggravated robbery.
Criminal law – murder and aggravated robbery – identification by CCTV – recognition by co-workers – corroboration by property found at scene and financial transactions – failure to produce call records – dereliction of duty not necessarily fatal where evidence is overwhelming – odd coincidence as supporting evidence.
19 August 2024
Whether the Director of Mining Cadastre may grant consent to enter titled surface land and proper appellate remedy.}
Administrative law; mining law – Director of Mining Cadastre’s power to grant consent to enter surface rights; procedural remedies and appeals under the Mines and Minerals Development Act; jurisdiction and leave to appeal under section 13 Court of Appeal Act.
19 August 2024
Mere unauthorised possession of a Defence Force uniform does not satisfy s6(1)(a); prosecution must prove prejudicial purpose.
State Security Act s6(1)(a) — unauthorised use/possession of Defence Force uniform — requirement of specific purpose (gain admission to protected place or purpose prejudicial to national safety/interests) — mere possession insufficient; Penal Code s182 inapplicable.
19 August 2024
Applicant failed to show statutory grounds for leave to appeal or for a stay; omitted grounds properly deemed abandoned.
Court of Appeal — leave to appeal to Supreme Court (s13(3)) — criteria: point of law of public importance; reasonable prospects of success; other compelling reasons — abandonment of grounds omitted from heads of argument — improper raising of unpleaded fraud — stay of execution dismissed.
19 August 2024
Whether the prosecutrix’s identification was sufficiently corroborated by admissions, medical evidence, and opportunity.
Criminal law — Defilement — Corroboration of identity and commission — Role of relatives’ evidence — Admissions and opportunity as corroboration — Safety of conviction.
16 August 2024
Failure to show gross negligence, respondent's accidental firearm discharge during hunting negates manslaughter.
Criminal law – Manslaughter by negligence – Defence of accident (section 9(1) Penal Code) – Burden on prosecution to disprove accident – Gross negligence/recklessness required – Failure to engage safety catch not per se manslaughter in hunting context.
16 August 2024
Court refused to dismiss the appellant's appeal for defective grounds but awarded costs to the respondent.
Appeal procedure – grounds of appeal – Order X r.9(2) CAR – non-compliance with rules (narrative/argumentative grounds) – jurisdiction – discretion to hear appeal despite defects – costs.
15 August 2024
Whether respondent bank conspired or breached a charge; court finds no bank liability and email did not waive charge.
Agency — agent's authority by conduct; Charge over bank account — enforceability and waiver by email; Conspiracy to defraud — requirement of combination and unlawful means; Unconscionability — setting aside oppressive interest clauses; Civil procedure — restraint on prolix heads of argument.
14 August 2024
A party seeking variation of a single judge’s decision must proceed by renewal, not by an appeal styled motion.
Civil procedure — Full court review of single judge decisions — Section 9(b) CAA and Order 10 r.2(8) CAR — Renewal of application to full court, not an appeal; procedural competence; registry clerical errors; consolidation and jurisdictional objections.
6 August 2024