High Court of Zambia - 2023

106 judgments

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106 judgments
Citation
Judgment date
August 2023
Court dismissed premature stay application pending appeal, vacated ex‑parte stay and granted leave to appeal.
Civil procedure — Stay of execution or proceedings pending appeal — Discretionary remedy; application premature where there are no proceedings to stay; appeals challenging findings of fact have limited prospects — assessment of damages and taxation of costs.
16 August 2023
Complainant awarded unpaid salary and statutory leave pay; gratuity and marking allowance claims dismissed.
Employment law – salary arrears – leave pay calculation under Employment Code Act – gratuity and effect of probation – duties included in salary (marking) – admissibility of handwritten evidence – costs for non-appearance.
11 August 2023
Ex‑parte leave to file out of time may stand; court’s discretion under s85(5) governs, not a mandatory inter‑partes hearing.
Industrial Relations Act s85(3) — extension of time; ex‑parte applications; audi alteram partem; substantial justice s85(5); delay and negotiations; statute‑barred actions.
5 August 2023
July 2023
Uncontested divorce granted on two-year separation; custody, maintenance and property settlement referred for formal application.
Family law – Divorce – Decree nisi where parties lived apart for two continuous years – Uncontested petition – Custody, maintenance and property settlement referred for separate formal applications – Costs each party to bear own.
27 July 2023
Redundancy lawfully effected; statutory minimum paid due to employer insolvency; complaint dismissed; each party bears own costs.
Employment law — Redundancy (s.55 Employment Code Act) — Collective recognition agreement and negotiation obligations — Consultation and genuine engagement — Proof of payment and burden of evidence — Employer financial incapacity/Bank of Zambia findings.
25 July 2023
2nd defendant lacked standing to discharge a garnishee nisi that expressly related only to the 1st defendant's accounts; application dismissed.
Garnishee proceedings – locus standi to set aside ex parte order – effect of stay of execution limited to named party – garnishee order relates to specified judgment debtor’s accounts – creditor equality and insolvency exceptions.
24 July 2023
Challenge to a termination notice falls under the Business Premises Act, but alternative claims requiring a writ preserve the Writ of Summons.
Landlord and Tenant (Business Premises) Act – mode of commencement; Originating Notice of Motion v Writ of Summons; challenge to notice to terminate under Sections 4–5; Order 14A (determination of question of law without full trial); Order 33(3) (triable issues); alternative remedies outside the Act; jurisdiction and competence of process.
12 July 2023
Written contract terms governed the parties; plaintiff awarded K8,455,157.80; theft claims partly statute-barred; limitation clause enforced.
Contract law – incorporation of written terms into oral agreement; limitation clauses – validity and enforceability; Limitation Act – six-year bar to tort/simple contract claims; set-off and equitable adjustment; interest and costs on judgment.
11 July 2023
Registrar granted leave under s85(3) to file an out-of-time complaint, finding the delay not deliberate and imposing a 14-day deadline.
Industrial Relations Act s85(3) – Registrar's discretionary power – Leave to file out-of-time complaint – Delay not deliberate – 14-day filing deadline.
10 July 2023
June 2023
Plaintiffs’ challenges to loan terms and requests for consolidation and injunction dismissed; defendant’s counterclaim succeeds with foreclosure nisi and judgment for K8,543,087.16.
Contract law – loan and collateral agreements – signature binds parties; consumer claims – unfair trading and extortionate terms not established; remedies – enforcement of signed credit contracts, foreclosure nisi, refusal to appoint receiver; awards – judgment for lender, nominal damages, interest and costs.
29 June 2023
Court orders valuation/sale and unequal apportionment of matrimonial assets, awards mortgaged Salama Park to petitioner and preserves pensions.
Matrimonial property – meaning of family property – contributions in money, material or in kind – property adjustment under Matrimonial Causes Act; Deed of Gift and effect on family property; valuation and sale of jointly acquired property; treatment of pension, gratuity, NAPSA and shares; apportionment of movable assets and liabilities.
29 June 2023
Court apportioned matrimonial assets: valuator sale/buy‑out for jointly titled land (Lusaka West 70/30), awarded mortgaged flats to petitioner, ordered transfers and itemised allocations.
Family property — property adjustment on divorce — non‑financial contributions (material/in kind) create equitable interest — valuation and sale or buy‑out options — treatment of gifts/transfers executed before/during proceedings — pensions, gratuities, shares and savings retained by their respective owners — need for finality and clean break.
29 June 2023
Plaintiff proved signed acknowledgements and recovered ZMW583,338.72; defendant ordered to pay within 90 days or collateral may be sold.
Civil recovery – village banking groups – enforceability of signed acknowledgements of debt; company limited by guarantee promoting savings; evidence and non-appearance; remedies including payment, interest and enforcement of pledged collateral.
29 June 2023
Court rejected remorse and youth mitigation, imposing life and lengthy concurrent and consecutive sentences for sustained abduction and rape.
Sentencing hearing; remorse and genuine contrition; youth and drug history as mitigation; gender-based violence; seriousness of prolonged abduction and continuous rape; concurrent vs consecutive sentences; imposition of life imprisonment for aggravated rape.
29 June 2023
Probation dismissals require statutory assessment and hearing; failure renders dismissal unfair, unlawful and compensable.
Employment law – probation – statutory procedural requirements (assessment, communication, right to be heard) – management status vs unionised employee – re‑designation under Minimum Wages and Conditions of Employment (General) Order – prohibition on contracting out of mandatory Employment Code provisions – remedies: damages, statutory underpayments, severance, interest.
22 June 2023
A legal practitioner’s failure to account client funds justified striking off; later reconciliation did not prevent discipline.
Legal practitioners – Professional misconduct – Failure to account for client funds – Service and notice to practitioner – Substituted service – Reconciliation not a bar to disciplinary sanction – Striking off roll.
16 June 2023
Court authorised an administrator to sell estate land under s19(2) after beneficiaries' consent and publication, with no objections.
Intestate Succession Act s19(2) – Administrator's power to sell estate property – Grant of Letters of Administration – Beneficiaries' consent – Publication of notice – No objections.
15 June 2023
Leave to appeal from Industrial Relations Division is unnecessary; appeal out of time granted and execution stayed pending appeal.
Civil procedure — Appeals from Industrial Relations Division — automatic right of appeal under Court of Appeal Act; extension of time to file appeal — discretionary relief on sufficient cause; stay of execution and stop sale of seized goods pending appeal to prevent nugatory relief.
13 June 2023
Court authorises administrators to sell estate land under s19(2) following title proof, publication and beneficiaries’ consent.
Intestate Succession Act s19(2) – Administrator’s authority to sell estate property – requirement of court authority – proof of estate title – publication of notice – beneficiaries’ consent – absence of objections.
9 June 2023
Court stayed proceedings pending determination of the defendant's application to set aside a consent judgment and consolidate actions.
Civil procedure — Stay of proceedings — Order 3 rule 2 High Court Rules — Consent judgment affecting same subject property — Non-joinder and setting aside consent judgment — Consolidation to avoid multiplicity of actions.
1 June 2023
May 2023
Failure to serve a Section 13 notice of intention to re-enter rendered the council's repossession and reallocation invalid.
Property law – lands re-entry and repossession – Section 13 Lands Act – requirement to serve notice of intention to cause certificate of re-entry and afford three months to make representations – service by registered post – invalidity of re-entry without compliance; reliefs including cancellation of allocation, direction to effect transfer swap, and assessment of improvements to prevent unjust enrichment.
29 May 2023
Claim of constructive/unfair dismissal failed: plaintiff never resigned and lacked evidence to prove emoluments or statutory termination.
Employment law – constructive dismissal requires resignation or notice in response to employer's repudiation; suspension is not termination – unfair dismissal requires statutory breach – courts should not award pay for unworked suspension periods without conditions of service (risk of unjust enrichment) – court-ordered termination subject to statutory referral procedures – interlocutory relief under Order 3 Rule 2 requires an enabling provision.
23 May 2023
Whether a notice of intention to arbitrate suffices to commence arbitration and avoid six-year limitation.
Arbitration jurisdiction; notice of intention to arbitrate; construction of contractual dispute-resolution clause (Clauses 8.1 & 10.2); commencement of arbitral proceedings (UNCITRAL Article 3); limitation — Limitation Act 1939 (six years); court review of interim jurisdictional ruling under Arbitration Act Article 16(3).
11 May 2023
Plaintiff’s 0.5% success-fee claim dismissed; entitled to 0.140% only upon first project financing drawdown.
Agency / letter of authorisation – contract by conduct – quantum meruit considered but contract by conduct found – success fee conditional on project financing/first drawdown – prior payments characterised as consultancy/commission – claim for 0.5% dismissed; entitlement to 0.140% accrues after first drawdown.
8 May 2023
Court granted a mandatory interim order compelling the university to secure inspected, fit learning spaces to protect students' right to education.
Education rights – over‑enrolment and inadequate learning facilities – mandatory interlocutory injunction – exceptional remedy – irreparable harm – best interests of the child – balance of convenience.
8 May 2023
Arbitration rules govern award registration and service; court registration cannot alter an arbitral award—share‑register amendment set aside.
Arbitration law – Registration and enforcement of foreign arbitral awards – Arbitration Act and Arbitration (Court Proceedings) Rules govern registration and service – service out of jurisdiction under Rule 19 – mandatory 90‑day set‑aside period (Rule 17) is formal requirement but omission is curable – Court’s complementary role to arbitration does not permit altering an award (orders directing amendment of share register set aside).
4 May 2023
April 2023
30 April 2023
Warrants of seizure (s58) differ from restriction notices (s60); CPC governs warrants and proof on oath need not be a filed affidavit.
Anti-Corruption Act s58 (warrant of seizure) vs s60 (restriction notice) – Distinct effects; Criminal Procedure Code governs warrants obtained in investigations; proof on oath to magistrate suffices (no filed affidavit required); lower court misapplied civil filing rules; appellate competence where appeal arises from non-criminal-origin proceedings.
21 April 2023
Written sale with buy-back option, not a loan; plaintiff failed to prove repayment, specific performance and damages awarded to defendant; repayment ordered net of damages.
Property law – contract of sale with buy-back option – interpretation of written agreements; inadmissibility of extrinsic evidence to contradict clear contract terms; caveat and remedy under Lands and Deeds Registry Act; specific performance for contracts of land; unjust enrichment and repayment of monies paid towards a buy-back.
21 April 2023
Court held the parties executed a sale with a buy-back option, not a loan, denying caveat removal and granting specific performance.
Property law – contract of sale with buy-back option vs. secured loan; construction of written agreements; admissibility of extrinsic evidence; caveat removal; specific performance; assessment of redemption/extension charges.
21 April 2023
Seizure notices under the Anti‑Money Laundering Act must be served and justified by the State’s reasonable belief; otherwise they are invalid.
Seizure of property — Prohibition and Prevention of Money Laundering Act, s.15 — burden of proof on authorised officer to demonstrate reasonable belief of proceeds of crime; requirement of service of seizure notice to affected person; seizure notice validity interpreted as six months (s.18); right to be heard and presumption of innocence; High Court jurisdiction to entertain challenges to seizures.
21 April 2023
Third‑party restriction notices under section 61 take effect upon service on the third party; banks must comply.
Anti‑Corruption Act s60 v s61 — third‑party restriction notices — service on bank — effect from service on third party — bank’s duty to comply; customer‑banker relationship; lawful exercise of investigative powers.
20 April 2023
Eyewitness identification proved murder beyond reasonable doubt despite missing physical exhibits and allegations of investigative shortcomings.
Criminal law – murder – proof beyond reasonable doubt – eyewitness identification and identification parade – partisan witnesses and corroboration – missing exhibits and dereliction of duty – defence of self‑defence not pleaded.
5 April 2023
Sitting tenants (including subsidiary and seconded employees) have first priority to purchase houses; wrongly issued titles may be cancelled.
Property law — parastatal house disposals — sitting tenant priority to purchase; irregular conveyancing in face of injunctions and caveats; cancellation of wrongfully issued titles; equitable protection for bona fide purchasers for value; dismissal of counterclaim.
1 April 2023
March 2023
Contract suspension under an express clause upheld; plaintiff failed to prove claimed losses; defendant's K12,792 counterclaim succeeds.
Contract law – distributorship – suspension versus termination – clause permitting suspension for non-payment; civil burden of proof – claimant must prove special losses with transaction-specific evidence; weight of reconciliation documents and unsigned communications; counterclaim established by final reconciliation.
29 March 2023
Court dismissed insurers' application to refer dispute to arbitration and rejected enforceability challenge based on a repealed Insurance Act.
Arbitration clause — Order 14A preliminary determination — choice of forum — forum non conveniens — contested factual disputes and allegations of fraud — jurisdictional limits — enforceability under Insurance Act (repealed provision) — dismissal of premature challenge.
29 March 2023
21 March 2023
Committee’s annulment of all elections using unadopted draft rules and without hearing affected persons was unlawful and quashed.
Administrative law – judicial review – internal disciplinary/electoral bodies – amenability to review (Datafin) – excess of jurisdiction – use of unpromulgated draft rules – breach of natural justice – Wednesbury unreasonableness.
6 March 2023
Plaintiff's premature rescission barred specific performance; deposit refundable; defendant awarded nominal damages and assessed legal fees.
Contract law – rescission and anticipatory breach – premature rescission bars specific performance; withholding deposits and unilateral deductions require contractual authority or judicial determination – damages and legal fees recoverable but must be proved/assessed.
6 March 2023
Whether the applicant's challenge to a public body's suspension must proceed by judicial review with leave or by writ.
Administrative law — Judicial review v. ordinary civil action; leave requirement (Order 53); Order 14A and Order 33 (preliminary issues/strike out); declarations and damages; procedural impropriety, illegality, irrationality; when full trial/viva voce evidence is required.
4 March 2023
February 2023
Court held receivers’ appointment void for failure to satisfy debenture notice/crystallisation prerequisites; conveyances tainted but some titles protected.
Company/Receivership – validity of receiver appointment – continuing floating debenture – crystallisation and notice required; Debenture law – events of default and seven‑day execution rule; Property law – void conveyance by invalid receiver; Bona fide purchaser doctrine and lis pendens; Reliefs – declaratory reliefs, rescission, damages (nominal awarded).
28 February 2023
Leave to appeal granted; stay refused because the judgment did not grant an enforceable remedy and the arbitral award was not stayable; writ of fieri facias set aside.
Arbitration: leave to appeal; stay of execution — judgment dismissing challenge to arbitral award not stayable; arbitral awards become enforceable as court orders once set-aside period expires or application refused; courts lack jurisdiction to stay awards they did not render; registration and enforcement of awards to be pursued in same court/process; irregular writ of fieri facias set aside.
28 February 2023
Summary determination under Order 14A refused where disputed oral loan, certificate status and vehicle sale issues required a full trial.
Procedure — Order 14A (summary determination) — procedural prerequisites and suitability for determination; Contract law — enforceability of oral money‑lender agreements post Money Lenders Act; Security v sale — whether vehicle sale was collateral; Interest — validity of 30% per month; Evidence — disputes of fact require full trial.
22 February 2023
Whether Cabinet Circular No.3/2001 binds statutory bodies and entitles seconded civil servants to equivalent employment terms.
Administrative law – Cabinet Office Circulars – binding effect on statutory bodies; Employment/contract law – secondment – clause 2(g) interpretation; Remedies – assessment of back pay, interest and costs.
21 February 2023
Employer failed to prove bona fide operational requirements; terminations were unfair and damages awarded (five months' salary each).
Employment law – redundancy v. termination – operational requirements – burden of proof on employer under s.52(5) Employment Code Act – unfair/unlawful dismissal – damages.
13 February 2023
Employer dismissed employees without charge or hearing; dismissals held wrongful and unfair, awarding 24 months' salary as damages.
Employment law – Employment status – wrongful and unfair dismissal – breach of natural justice and s.52(3) Employment Code Act – damages (24 months’ salary) – suspension without pay – costs for unreasonable delay.
10 February 2023
Employment performed in Zambia is governed by Zambian law; summary dismissal without a hearing is unfair and attracts damages.
Employment law – Governing law for contracts performed in Zambia – Incorporation of external terms – Wrongful v. unfair dismissal – Requirement to give valid reasons and hearing before summary dismissal – Remedies: damages, notice pay, return of employer property – Counterclaim must be pleaded.
3 February 2023
January 2023
Plaintiff failed to prove claimed hire charges; parties’ conduct showed payment was due only for actual days worked.
Contract interpretation — hire of plant equipment — admissibility of surrounding circumstances and conduct to determine commercial intention — burden of proof in civil claims — whether charges payable per actual days worked or for entire custody period.
31 January 2023
Claims challenging a provisional liquidator’s acts, including alleged illegality of remuneration, must be pursued within the pending winding up proceedings.
Corporate insolvency – Liquidation – Jurisdiction to challenge acts of liquidator – Disputes as to remuneration, account and alleged misfeasance must be raised in winding up proceedings; multiplicity of actions disapproved.
27 January 2023
Whether rejection of the applicant's nomination and subsequent timing issues rendered the by-election void.
Electoral law — nomination challenges (Article 52(4)) — nullification grounds (s.97(2)(b) EPA) — nullification vs disqualification (Art.72(4)) — effect of lapse of 21‑day period — Article 52(6) resignations and fresh nominations — abuse of process.
24 January 2023