High Court of Northern Rhodesia

162 judgments
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162 judgments
Citation
Judgment date
December 1964
A transfer under s.73(a) requires a de novo trial; transfers solely for sentencing are ineffective.
Criminal procedure — s.73(a) transfer requires de novo trial; transfer solely for sentence ineffective — s.128 bars retrial after conviction — convicted but unsentenced prisoner may be sentenced by a different magistrate sitting in same court.
23 December 1964
Court allowed amendment to add permanent maintenance after decree absolute, exercising discretion despite respondent's complaint of being misled.
Divorce procedure – amendment of petition after decree absolute – adding prayer for permanent maintenance – discretionary relief; omission potentially misleading respondent a relevant but not decisive factor (Aggett v Aggett).
10 December 1964
The applicant’s part-year residence and limited local activities determined supertax liability on dividends.
Income tax – interpretation of "ordinarily resident" and "carrying on business" – s.86(2)(a) proviso – part‑year residence and limited corporate/letting activities do not suffice for exemption.
4 December 1964
November 1964
Court may examine pre‑divorce settlements for collusion but cannot grant formal approval; fuller affidavit required.
Divorce — pre‑petition property settlement — collusion — s.4(3) Matrimonial Causes Act 1963 — rule 2A Matrimonial Causes Rules — court may determine collusion and give directions, not formally approve agreements.
23 November 1964
September 1964
Whether an accused must testify before other defence witnesses under section 191 and if refusal causes miscarriage of justice.
Criminal procedure – Order of calling defence witnesses – Whether accused must give evidence before other defence witnesses – Construction of section 191 Criminal Procedure Code (directory vs mandatory) – Substantial miscarriage of justice – Counsel’s tactical choices.
4 September 1964
August 1964
Sections 5 and 9(1) require knowledge; the applicant's unknowingly entering the park warranted acquittal.
Statutory construction – presumption of mens rea – displacement only by clear words or necessity to suppress mischief; Criminal law – strict/absolute liability; Game Ordinance (s.5, s.9(1)) – unlawful entry and possession of arms require knowledge; Appeal – convictions quashed where magistrate misapplied absolute liability precedent.
31 August 1964
July 1964
Whether the Commissioner improperly prioritised railway interests and whether third‑party intentions may negate direct adverse effects under section 152.
Road traffic law – exercise of statutory discretion under s.152 – matters to be balanced, no primacy for railway interests; appellate jurisdiction under s.155 limited to questions of law; evidence of third‑party future intentions irrelevant to direct adverse effect assessment.
31 July 1964
Criminal courts may question deportation orders; magistrates must investigate birth/status claims before accepting guilty pleas.
Deportation — jurisdiction to question validity of deportation orders — acceptance of guilty pleas where birthplace or British-protected status is asserted — proper statutory charge (Deportation Act v Immigration Act).
21 July 1964
June 1964
Similar offences may be taken into consideration at sentencing but must not attract separate convictions or sentences; excessive sentence reduced.
Criminal law – Sentencing – Offences taken into consideration – Similar offences may be considered in mitigation but must not be separately convicted and sentenced; appellate intervention where sentence gives a 'sense of shock'.
25 June 1964
May 1964
Non‑compliance with section 192 makes an amendment irregular (saveable under s323), but material evidential variances caused a substantial miscarriage of justice.
Criminal procedure — Amendment of charge — Non‑compliance with section 192 (time of amendment, right to recall witnesses, re‑arraignment) — Irregularity not jurisdictional; section 323 — appellate protection where no substantial miscarriage of justice — Variance between charge and evidence — credibility and substantial miscarriage of justice — trial irregularities (prosecutorial misconduct, improper re‑examination, delay).
28 May 1964
Court granted extension under section 73 but warned it will closely scrutinise and not routinely excuse statutory defaults.
Companies law – Registration of return of allotments – Section 73 Companies Ordinance – Court discretion to extend time – Not a rubber stamp – Excuse of 'extreme pressure of work' scrutinised – Companies' responsibility to comply with filing obligations.
25 May 1964
April 1964
Court excluded the accused's statements: prosecution must prove confessions were voluntary and not induced by authority.
Criminal procedure – admissibility of confessions – voluntariness – burden on prosecution to prove absence of inducement by person in authority – inducement broadly defined (threats, promises, prolonged questioning) – prior inducement may taint subsequent statements – fresh caution required.
25 April 1964
A cheating offence under section 280 does not require the fraudulent device to be aimed at the public at large.
Criminal law – Cheating (s.280 Penal Code) – fraudulent trick or device need not be calculated to affect the public at large – precedent in Mukese v Reginam held per incuriam and not binding – assessment of documentary evidence and witness credibility.
13 April 1964
Whether orders under a writ of elegit bind a private sale and whether defective orders are void or voidable.
Writ of elegit – sale by judgment creditor – requirement for judicial directions and approval of contract – distinction between void and voidable orders for lack of service – supplemental orders must be made in original proceedings – payment of purchase money into court.
10 April 1964
High Court quashes inadequate magistrate sentence for drunken driving and substitutes immediate custodial sentence and longer licence suspension.
Road traffic — Drunk driving — Adequacy of sentence — Reoffending after prior drunken-driving conviction — Suspension of licence and effect on suspended sentence — Review under s.8 Criminal Procedure Code.
9 April 1964
March 1964
Death of a spouse before decree abates divorce; court may only apply pre-existing deposited funds to prior costs.
Divorce — abatement by death of spouse — no jurisdiction to make new costs orders after abatement — court may apply funds deposited under existing costs order.
11 March 1964
Self-defence raised reasonable doubt; prosecution failed to disprove lawful homicide, so the accused was acquitted.
Criminal law — Murder and manslaughter — Self-defence — Justificable vs excusable homicide — Elements: honest belief and reasonable necessity — Duty to retreat for non-forcible assaults — Burden on prosecution to disprove self-defence where reasonable possibility exists — Accused's silence and witness credibility.
5 March 1964
February 1964
Aider-and-abettor of dangerous driving can be convicted and must face licence suspension absent special, offence-related reasons.
Causing death by dangerous driving; aiding and abetting negligence; suspension/disqualification of driving licence mandatory on conviction; "special reasons" must be special or unusual to the offence; section 21 Penal Code applies to offences under statutory law.
24 February 1964
Creditors have no general right to attend or cross-examine at private section 25 bankruptcy examinations.
Bankruptcy — section 25 examinations — private/inquisitorial proceedings before registrar — no right for creditors to attend or to cross-examine — counsel for examinee permitted — limited retention/disclosure of notes.
14 February 1964
Territorial High Court granted certiorari quashing an improperly constituted statutory disciplinary tribunal and its confirmations.
Administrative law — Judicial review — Certiorari to quash — Tribunal improperly constituted — Statutory disciplinary procedure — Jurisdiction of territorial High Court over federal authorities — Duty to act judicially and natural justice.
3 February 1964
January 1964
Failure to specify particular goods in an attempted theft charge does not invalidate the conviction if the accused was adequately informed.
Criminal law – Attempted theft – Particulars of property – Whether specific goods must be specified in charge – Attempt to steal from a container includes attempt to steal its contents – Sufficiency of charge and prejudice to accused.
31 January 1964
Whether a class II subordinate court may enforce a High Court judgment exceeding its statutory £100 jurisdiction.
Subordinate court jurisdiction – class II monetary limit (£100) – enforcement of High Court judgments – transfer under s24(2) High Court Ordinance does not enlarge subordinate court jurisdiction (s24(3)) – s19(3) enforcement power limited to resident/senior resident magistrates – jurisdictional increase under s23.
8 January 1964
Threats to burn property are not legal compulsion; prosecution's omission to tender a bald denial did not prejudice the accused.
Criminal law — arson; compulsion under section 17 — present threat to life or grievous bodily harm required; joint charge vs indivisible offence; prosecutorial discretion to tender accused's statements; failure to tender may be ground of appeal if miscarriage of justice.
3 January 1964
June 1963
A taxing officer may exceed ordinary costs scale under Order XXXIV, rule 7; it differs from the court’s higher-scale discretion.
Costs — Taxing officer’s discretion under Order XXXIV, r.7 to exceed scale based on skill, labour and responsibility — Distinct from court’s power under Order I, r.6A requiring special grounds — Review of taxation refused.
6 June 1963
April 1963
Arrest without warrant was lawful where officer had reasonable grounds under s.22(g) and the Fugitive Offenders Act applied.
Habeas corpus — legality of warrantless arrest under s.22(g) Criminal Procedure Code — reasonable grounds from telegraphic signal — applicability of Fugitive Offenders Act 1881 — duty to inform arrested person truthfully — procedural irregularity in affidavit not fatal.
27 April 1963
March 1963
A magistrate's court has inherent jurisdiction to punish for contempt where a person fails to attend a judgment summons.
Contempt of court – failure to attend a judgment summons – Order 38 r.15 and s.44 Subordinate Courts Ordinance – s.99 Penal Code (summary contempts) – inherent jurisdiction of a court of record to punish contempts in its face – magistrate’s summary punishment upheld.
23 March 1963
June 1949
An unregistered lease required by statute is of no effect; it cannot be enforced or used to fix a yearly tenancy's commencement.
Lands and Deeds Registry Ordinance — non-registration renders instruments "null and void" with no legal or equitable effect — unregistered leases unenforceable — estoppel not available absent fraud — notice doctrine excluded by statute — yearly tenancy commences on date of entry and payment.
1 June 1949
An unregistered lease under the Registry Ordinance is wholly void and cannot fix tenancy commencement; no estoppel absent fraud.
Lands and Deeds Registry Ordinance — effect of non-registration — "null and void" means no effect in law or equity — unregistered lease not enforceable nor able to fix commencement of tenancy — tenancy from year to year arises from entry and payment of annual rent — estoppel only where fraud or inducement — section 7 excludes notice of prior unregistered documents except for actual fraud.
1 June 1949
December 1942
Leave to serve a tort writ abroad was set aside due to territorial law and foreign sovereign immunity considerations.
Service out of jurisdiction — discretion of court — tort actions against foreign sovereigns — territorial law governs availability of suit — foreign Crown immunity and caution in granting leave.
31 December 1942
A mining regulation forbidding entry by "unauthorised persons" was void for vagueness; an invitee by an employee was authorised.
Mining regulations — Regulation 12 — "unauthorised person" — vagueness/indefiniteness — statutory interpretation — invitation by employee as authorisation — criminal conviction quashed.
31 December 1942
An accidental intervening act (slipping weapon) can negate murderous intent and reduce liability to manslaughter.
Criminal law – Murder v. manslaughter – requisite intention – intervening accidental act (slip) negating specific intent – causation – role of intoxication and provocation in assessing mens rea.
31 December 1942
Proof of a general deficiency alone cannot sustain an embezzlement conviction; particulars must specify the sum.
Criminal law – Embezzlement/theft – Proof of general deficiency insufficient – Particulars must specify the gross sum (and relevant dates) – Repeal of s.174 Criminal Procedure Code removes authority for charging on general deficiency.
31 December 1942
Embezzlement particulars must specify a gross sum; related offences' sentences should be concurrent, totaling 21 months IHL.
Embezzlement — general deficiency: particulars should state specific gross sum; proof of some larceny item required; practice upheld despite repeal of s.174; related sentences should run concurrently.
31 December 1942
Separate sentences ordinarily required per count; housebreaking and theft from same premises may be charged in one count.
Criminal law – Sentencing – Separate sentence for each count – Concurrent sentences permissible – Housebreaking and theft from same premises may be charged in one count.
31 December 1942
Court ordered 21-day medical observation to determine whether a deaf-mute accused is non-sane before sustaining a guilty finding.
Criminal procedure — Deaf-mute accused — Medical observation to determine sanity — Application of The King v Governor of Stafford (1909) — Procedure under Criminal Procedure Code ss.156 and 151(4) — Incapacity to enter defence
31 December 1942
December 1941
Leave-pay credits are contingent liabilities not deductible; genuine salary payments to a director are deductible; disguised profit distributions are taxable.
Income tax – deductibility – leave pay credited to suspense account is a contingent liability, not an outgoing incurred – annual sums to shareholder-director may be salary and deductible – amounts described as directors’ fees but effectively profit distributions are not deductible.
31 December 1941
Religious ceremony plus cohabitation can prove marriage in divorce cases when documentary proof is unobtainable.
Proof of marriage — Jewish marriage ceremony and cohabitation — presumption of validity in civil divorce when documentary proof unavailable — stricter proof required in bigamy prosecutions — desertion where wife refuses husband's chosen matrimonial home.
31 December 1941
Mandamus granted where statutory valuation objections were late but refusal would cause substantial and irremediable injustice.
Mandamus — discretionary remedy where no other adequate remedy exists; Valuation procedure — statutory requirement of six clear days' written notice under Cap. 26 s.26F; Magistrate's discretion to refuse late objections; No review under Subordinate Courts rules when acting as valuation court; Equitable grant of mandamus subject to conditions and costs.
31 December 1941
A solicitor in person recovers ordinary party-and-party costs but cannot charge for self-instruction or unnecessary items.
Solicitor appearing in person — recovery of party-and-party costs — disallowance of charges for self-instruction and unnecessary items — taxation of costs — allowance of mileage service fee — appeal costs.
31 December 1941
Wilful default to pay tax for multiple years under s.14(1)(a) constitutes a single offence, permitting only one count.
Native Tax Ordinance s.14(1)(a) – wilful default to pay "any tax" – unpaid tax for multiple years constitutes a single offence – only one count permissible; subsequent defaults after conviction are new offences.
31 December 1941
Section 287 applies only where a person in public (street/road) loiters or acts suspiciously with suspected stolen property.
Penal Code s.287 — possession or conveying of property reasonably suspected to be stolen — limited application where person is in street/road or loitering — requirement of suspicious appearance/actions attracting attention — "having" ejusdem generis with "conveying" — proper form of charge; accused's explanation not part of charge.
31 December 1941
Court affirmed prima facie proof for juvenile theft, held animus furandi at time of conversion, and substituted corporal punishment with conditional discharge.
Juvenile offenders — capacity of child under 12 to know wrongfulness (s.15 Penal Code) — prima facie proof from recent possession and implausible explanation — animus furandi assessed at time of conversion under local Penal Code — Juvenile Court sittings procedure — lawfulness of corporal punishment on juveniles — sentencing discretion and child’s best interests.
31 December 1941
A dangerous driving conviction was quashed because the statute protects highway users, not passengers inside the vehicle.
Motor traffic — Dangerous driving — Statutory construction — Provision protects persons using the highway (public), not vehicle occupants — Troughton v. Manning (1905) binding precedent — Conviction quashed
31 December 1941
Conviction under the townships noise regulation cannot stand where only an on‑duty policeman, not an annoyed private person, is relied upon.
Townships Regulations s.4(9) – making noise to the disturbance of a person – requirement that an annoyed person be shown – on‑duty policeman not ordinarily the protected "person" – insufficient evidence vitiates conviction.
31 December 1941
Section 72 may be invoked for s64 complaints; proceedings under s64 are criminal in form.
Employment of Natives Ordinance ss64, 72 – Application of s72 where specific penal sections repealed – Magistrate’s power to rescind contract and impose fines – Proceedings under s64 are criminal in form.
31 December 1941
The respondent's failure to take his wife to hospital did not amount to failing to supply "necessaries of life" under section 209.
Criminal law – Penal Code s.209 – "necessaries of life" limited to items such as food, water and clothes – failure to obtain medical treatment not within s.209; Penal Code s.214 – omission of duty causing harm may apply where accused knew medical assistance available; Criminal Procedure Code s.168(2) – conviction cannot be altered to a substantially different offence.
31 December 1941
The Crown can be a complainant and be ordered to pay compensation for frivolous or vexatious prosecutions under section 162.
Criminal procedure — s.162 compensation for frivolous or vexatious charges — Crown as complainant — distinction between costs and compensation — s.160 costs immunity — prosecutorial direction and vexatious prosecution.
31 December 1941
Section 158(4) requires both suspicious character and suspicious conduct; mere presence in hospital beds does not satisfy the subsection.
Penal Code s.158(4) – Rogue and vagabond – offence requires both 'suspicious character' and 'suspicious manner' – provision contemplates 'wandering' near premises; mere presence in hospital wards not covered.
31 December 1941
Conviction on circumstantial evidence quashed where proved facts did not exclude all reasonable inferences of innocence.
Criminal law – Circumstantial evidence – Sufficiency – Inference must be consistent with all proved facts and must exclude every other reasonable inference; conviction quashed where only suspicion established.
31 December 1941
Error in contravening an absolute statutory price prohibition is no defence, but may mitigate sentence.
Statutory offences – absolute prohibition – absence of mens rea no defence; strict liability for price-control breaches; mistake mitigates sentence only.
31 December 1941