Industrial Relations Division

92 judgments

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92 judgments
Citation
Judgment date
September 2025
Complainant failed to prove constructive dismissal; retirement benefits correctly computed on substantive Management Accountant grade.
Labour law – constructive dismissal – probationary confirmation assessments – role of supervisor and managing director – computation of terminal benefits on substantive salary.
19 September 2025
July 2025
Dismissal found wrongful; unpaid salaries, accrued leave and gratuity at 25% payable; four months' salary awarded for wrongful dismissal.
Employment law — termination — resignation v dismissal — wrongful dismissal for failure to afford hearing; entitlement to unpaid wages and accrued leave — fixed-term contract gratuity — Employment Code s.54(1)(c) overrides less favourable contractual term, granting 25% severance — interest and assessment by Registrar.
9 July 2025
November 2024
Claims for breach, gratuity and unworked‑period salary were dismissed where dismissal followed repeated unauthorized strikes and dues were paid.
Labour law – unauthorized strikes – dismissible misconduct; proof of breach of contract; entitlement to remuneration for periods not worked; Ministerial minimum wage categorisation.
28 November 2024
Whether the Labour Commissioner lawfully cancelled the applicant union's registration while court proceedings on its validity were pending.
Labour law — Trade union registration — Cancellation of certificate by Labour Commissioner — Effect of pending litigation on recognition and union activity — Section 12 and section 13(4)(a) Industrial and Labour Relations Act — Restoration of registration and costs for non-appearance.
25 November 2024
A minor, non-prejudicial amendment filed without leave was treated as properly before the Industrial Relations Division; matter to proceed on merits.
Industrial Relations Court – Pleadings – Amendment of answer – IRC Rule 36 and Rule 55 – High Court Rules inapplicable to IRD – White Book applicable only to lacunae – Validity of pleadings signed by in-house counsel – Substantial justice over procedural technicality.
21 November 2024
Minor amendment to respondent's answer filed without leave held valid; IRD procedure governed by IRC rules, White Book only fills lacunae.
Industrial Relations Court procedure – amendment of pleadings – Rule 36(5) IRC and Rule 55 IRC – applicability of High Court Rules to IRD – English White Book as gap-filler only – validity of pleadings signed by counsel – substantial justice over technicalities.
21 November 2024
Complainant proved employment and entitlement to statutory 25% severance; specific severance and salary-arrears claims dismissed for lack of proof.
Employment law – existence of employment relationship; Employment Code Act 2019 s54 – statutory severance (25% gratuity); burden of proof on claimant for salary arrears; accrued leave quantification in absence of records.
15 November 2024
Whether complainants dismissed during probation proved entitlement to unpaid salaries, leave or allowances; only one claimant succeeded.
Industrial relations — oral employment contracts — dismissal during probation — salary arrears — burden of proof and abandonment of claims — entitlement to leave and allowances — interest on awards (Bank of Zambia Short Term Lending Rate; thereafter 6%).
15 November 2024
Court found dismissal reasonable for withdrawal of labour; unfair dismissal claim dismissed.
Employment law – Alleged illegal strike/withdrawal of labour – Reasonableness test for dismissal – Employer’s disciplinary power – Unchallenged disciplinary minutes as evidence.
13 November 2024
Claim for wrongful/unfair dismissal dismissed; disciplinary process found fair and mental anguish unproven.
Employment law – disciplinary procedure – wrongful dismissal – unfair dismissal – double claiming of imprest/duplicate payments – requirement of proof for mental anguish damages; procedural fairness of domestic disciplinary hearings.
13 November 2024
Recognition agreement fixes employer’s duty to remit union subscriptions; pre-agreement arrears not recoverable; unpaid fees to be quantified.
Labour law – trade union subscription fees – recognition agreement crystallising employer’s obligation to remit subscriptions – recoverability of pre-recognition arrears – consequence of party’s non-appearance at trial.
12 November 2024
October 2024
Summary dismissal for gross negligence and prior misconduct was lawful; no damages for mental distress awarded.
Employment law — dismissal — gross negligence and accumulation of misconduct; unfair vs wrongful dismissal; procedural defects do not nullify dismissal where dismissible offence proven; damages for mental distress require unfair/wrongful dismissal and proof.
31 October 2024
Applicant awarded accrued leave and salary arrears; claims for terminal benefits and unfair dismissal failed for lack of proof.
Employment law — verbal employment — proof of employer/employee relationship; entitlement to accrued leave and unpaid salary arrears; failure to prove terminal benefits; proceedings in absence of respondent; interest on awards.
30 October 2024
Resignation was not constructive dismissal, but employer unlawfully compelled work post-resignation; gratuity and leave entitlements awarded.
Employment law — whistleblowing/protected disclosure — constructive dismissal — occupational detriment — unlawful continuation of employment after resignation — statutory (25%) and contractual (10%) gratuity — leave pay computation — performance bonus claim dismissed.
21 October 2024
Fixed-term employee awarded leave pay, phased gratuity, salary arrears and one month’s damages for constructive dismissal.
Employment law - fixed-term vs permanent contract; freedom of contract; constructive dismissal; statutory gratuity under Employment Code; entitlement to accrued leave and salary arrears; exclusions for management and collective agreements.
17 October 2024
Court dismissed challenge to audiovisual testimony, citing expedition, cost and complainant's health as justification for video evidence.
Evidence — audiovisual testimony; procedural discretion to permit video evidence; assessment of demeanour; risks of coaching or tampering; expedition, cost and health considerations.
15 October 2024
Complainant failed to prove unlawful dismissal, fringe benefit entitlements, or suitability for reinstatement; claim dismissed, leave to appeal granted.
Labour law — unfair/summary dismissal — burden of proof on employee to establish unlawful dismissal and contractual entitlements; constructive dismissal and fringe benefits; reinstatement an exceptional remedy, rarely granted, impracticable after long lapse.
11 October 2024
Whether the claimant proved a secured interest in goods seized in execution and who bears execution and interpleader costs.
Interpleader summons; notice of claim to goods taken in execution; burden on claimant to prove proprietary/secured interest; floating charge crystallization; validity of writ of fieri facias; sheriff's and interpleader costs.
9 October 2024
Refusal of an unsuitable redeployment amounted to redundancy; complainant awarded statutory redundancy package.
Employment law – redundancy under section 55 Employment Code Act – redeployment and suitability of alternative post – constructive dismissal as alternative remedy – employer identity and contractual transfer clause – proof of discrimination.
1 October 2024
Redeployment within contractual powers gave rise to statutory redundancy (effective 9 October 2021); constructive dismissal not established.
Employment law – employment identity of employer – interpretation of offer letter and contract – redeployment and redundancy under Employment Code Act s.55 – suitability of alternative employment – constructive dismissal and employer’s contractual power to transfer.
1 October 2024
September 2024
Employee unfairly dismissed without hearing; awarded one month's salary, accrued pay, 26 leave days and housing allowance.
Employment law — unfair dismissal for lack of hearing; deemed confirmation after probation — permanent employment; remedies: one month's salary damages, accrued pay, leave and housing allowance; gratuity, subsistence and risk allowance claims fail for legal/evidential reasons; counterclaim dismissed.
30 September 2024
Employer cannot withhold statutory benefits as compensation; termination requires valid reason, hearing and notice.
Employment law – termination versus dismissal; statutory requirements for termination (valid reason, opportunity to be heard, notice); gratuity as contractual term payable pro rata; contractual clauses withholding statutory benefits unenforceable.
30 September 2024
Interim injunction granted; exhaustion of union remedies did not bar court action and NEC's power to dismiss requires full hearing.
Labour/union law – exhaustion of internal remedies – scope of union constitution – power of NEC to dismiss elected officials – interlocutory injunction (American Cyanamid test) – adequacy of damages – balance of convenience.
17 September 2024
The respondent unlawfully deducted the complainant's terminal dues and underpaid gratuity; overtime claim lacked proof.
Employment law — gratuity calculation: use last drawn basic salary for the whole service period; employer deductions — employer must demonstrate contractual/legal authority and proof before recouping losses; burden of proof — claimant must produce evidence (approved forms/logs) for overtime claims; disciplinary/deduction fairness — need for proper procedural and evidential basis.
4 September 2024
August 2024
Applicant dismissed; not entitled to leave for 2006–2011 and terminal benefits claim unproven.
Employment law – termination of oral contract – resignation versus dismissal – notice; Leave entitlements – accrual requires six months’ continuous service; Terminal benefits – claimant must substantiate entitlement and quantum; Evidentiary weight – conflicting labour-office letters and burden of proof.
6 August 2024
Whether the applicant was dismissed or resigned and entitled to accrued leave and terminal benefits.
Employment law – oral contract – resignation v. dismissal – entitlement to accrued leave (continuous service requirement) – terminal benefits under section 21(b) – burden of proof and evidential substantiation.
6 August 2024
July 2024
Employer failed to prove operational requirements; termination unlawful—24 months' salary, severance and repatriation awarded.
Employment law – Termination for operational requirements – Employer must substantiate operational basis under s.52(2) Employment Code Act – Unlawful termination where employer fails to prove reorganisation – Damages: departure from normal notice award justified; severance pay and repatriation ordered.
17 July 2024
June 2024
Court upheld ex‑parte grant of leave to file labour complaint out of time; section 85(3) contains no time limit for the leave application.
Labour law – extension of time under s.85(3) ILR Act; ex‑parte application for leave to file complaint out of time; discretion to extend time; reasons must predate the 90‑day period; meritorious grounds include bona fide attempts to resolve and financial constraints when shown to have existed within the mandatory period.
18 June 2024
May 2024
Whether instant termination without following contractual disciplinary procedure and opportunity to be heard constitutes unfair and wrongful dismissal.
Employment law – substance over label: 'contract for service' found to be employment; dismissal v termination; summary dismissal; statutory right to be heard (s52(3)); breach of contractual disciplinary procedure (two warning letters); damages for unfair and wrongful dismissal; overtime claim requires proof of excess hours.
31 May 2024
Only the complainant with a post‑S.I.106 contract entitled to SI benefits; other underpayment claims dismissed.
Labour law – Statutory Instrument No.106/2020 – non‑retrospectivity of legislation; Employment Code – mandatory gratuity (25% of basic pay) for long‑term contracts; burden of proof on employee for underpayment; overtime requires proof of excess hours and employer approval; remedies – Registrar to assess proven underpayment; interest and costs.
24 May 2024
Employee awarded severance (post-transition), unpaid salaries, accrued leave, housing and lunch allowances; uniform bond claim dismissed.
Employment law – entitlement to severance pay under the Employment Code Act – effect of transition date (9 May 2020) – application of Minimum Wages and Conditions of Employment (General) Order 2011 – awards for unpaid salaries, accrued leave, housing and lunch allowances – defaulting respondent; burden of proof.
13 May 2024
April 2024
Summary dismissal upheld; complainant awarded only unpaid salary and accrued leave (K1,332); other terminal benefits dismissed.
Employment law – Summary dismissal – Disciplinary procedure under collective agreement – Entitlement to unpaid wages and accrued leave – No gratuity or severance where no long-term contract or qualifying category under Employment Code Act (sections 51, 54, 73).
30 April 2024
The respondent lawfully dismissed the complainant for dishonesty in diverting stock; reinstatement and damages denied.
Employment law – dismissal for misconduct/dishonesty – diversion of stock to indebted distributors – disciplinary procedure followed – wrongful and unfair dismissal claims dismissed – no costs awarded.
24 April 2024
Employees awarded accrued leave, prorated gratuity, limited salary arrears, notice pay and one month's damages for unlawful termination.
Employment law — long-term contracts — accrual and pay of leave; statutory pro rata gratuity on premature termination (s.73 Employment Code Act); proof required despite respondent's absence; unlawful/unfair termination requires valid reasons — damages measured by notice period.
15 April 2024
Dismissal upheld as neither wrongful nor unfair; employer's counterclaims dismissed for insufficient evidence.
Employment law – wrongful versus unfair dismissal; application of disciplinary code and procedural fairness; evidential burden for counterclaims; dismissal supported by documentary evidence and admission.
10 April 2024
Court found retaliatory dismissal for suing over unpaid wages unlawful, awarding one month's notice, accrued leave and 12 months' exemplary salary each.
Employment law – dismissal v termination – procedural fairness and natural justice – wrongful, unlawful and unfair dismissal – notice pay; terminal benefits (accrued leave); exemplary damages for non-remittance of pension contributions; interest and costs; leave to appeal granted.
3 April 2024
Contractual notice termination lawful absent malice, but unilateral reduction of pay constituted breach—six months' damages awarded.
Employment law – Contractual termination clause – Distinction between termination and dismissal – Court's power to look behind termination for substantial justice – Unilateral variation of wages and allowances without consent – Breach of contract – Damages for breach (six months' salary).
3 April 2024
March 2024
Termination by notice was unlawful without valid reason; employee entitled to accrued leave, statutory severance/gratuity and damages.
Employment law – accrued leave entitlements; gratuity and severance – effect of enactment of Employment Code and temporal application; minimum wage overrides lower contractual basic pay; termination by notice must be accompanied by valid substantiated reasons – failure renders termination unfair; employer liability for off-premises accident requires causal connection.
7 March 2024
February 2024
Complainants awarded leave pay, gratuity and uniform bond refund; most other employment claims dismissed for lack of merit.
Employment law – termination for misconduct (abandoning post) – applicability of exhibited conditions of service – entitlement to accrued leave pay – contractual gratuity payable on termination – no notice pay where dismissal permitted by disciplinary code – allowances and minimum wage claims displaced by collective bargaining – refundable uniform security bond – compassionate leave and funeral grant non-applicable/ non-retroactivity of Employment Code – insufficient evidence for overtime/night/public holiday pay or monetary conversion of mother's days.
27 February 2024
The complainant was wrongfully terminated from a mine‑linked long‑term contract and awarded 24 months' salary.
Employment law – contract characterisation (life‑of‑mine long‑term contract) – confirmation letter and variation – wrongful termination for breach of contract and failure to give valid substantiated reason – jurisdiction preserved despite partial Ministry settlement – damages awarded (24 months' salary) – interest and costs.
23 February 2024
23 February 2024
Employer failed to charge and meaningfully hear employee; dismissal was wrongful and unfair, awarding 18 months' salary plus arrears and allowances.
Employment law – disciplinary procedure – suspension and summary dismissal – necessity of written charges, particulars and formal hearing; burden on employer to prove valid reason; remedies for wrongful and unfair dismissal (damages, back pay, recovery of underpayments); gratuity entitlement under pre‑2019 law.
16 February 2024
Employee suspended pending investigation not dismissed; entitled to September salary and accrued leave but failed to prove underpayments or redundancy.
Employment law – suspension vs dismissal; accrued rights – salary and leave pay; burden of proof for underpayments; redundancy claims under SI No.2/2011; admissibility of uncommissioned affidavit where deponent testifies orally; costs – each party to bear own.
15 February 2024
Whether a worker was a permanent protected employee entitled to leave pay, gratuity and notice pay.
Employment law – determination of employment status (permanent vs seasonal) – protected worker – application of Minimum Wages and Conditions of Employment (General) Order 2011 (as amended) – entitlement to accrued leave pay and gratuity – severance pay conditions (10 years and age 55) – notice pay – burden of proof for compensation for workplace injury.
6 February 2024
January 2024
Complainant found to have absconded; awarded accrued leave and limited severance; counterclaim for bus damages dismissed.
Employment law — summary dismissal for unauthorised absence — entitlement to accrued leave pay — severance pay payable to permanent employees from transition date (9 May 2020) — employer deduction for failure to serve notice — counterclaim for vehicle repair and loss requires proof on balance of probabilities.
29 January 2024
Employee entitled to leave, notice, statutory underpayments and allowances; severance claim dismissed.
:[
29 January 2024
Employee wrongfully and unfairly dismissed without charge or hearing; awarded nine months' pay and unpaid accrued leave balance.
Employment law – wrongful and unfair dismissal – procedural fairness (natural justice, section 52(3) Employment Code Act) – proof of salary arrears and salary advance records – accrued leave entitlement – measure of damages (departure from notice period).
26 January 2024
Sleeping on duty found to justify dismissal; employee entitled to one month’s pay in lieu of notice but not other damages.
Employment law – Termination – Resignation versus dismissal – Sleeping on duty as misconduct – Unfair dismissal standard – Entitlement to payment in lieu of notice – Burden of proof for damages.
11 January 2024
December 2023
Employee awarded accrued leave, gratuity, pay for days worked and notice pay; claim for future salaries dismissed.
Employment law — contractual leave pay; statutory calculation of leave benefits; contractual gratuity (25% of basic pay); salary arrears for days worked; future salary claims as unjust enrichment; notice pay; hearing in absentia where respondent aware.
26 December 2023
Complainant failed to prove an employment relationship; employment claims dismissed and hire counter-claim dismissed for lack of jurisdiction.
Employment status — employee vs independent contractor — control test and whether work is integral to employer's business — burden of proof in employment claims — jurisdictional limits of Industrial Relations Court for commercial hire disputes.
20 December 2023