High Court of Northern Rhodesia - 1938

14 judgments
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14 judgments
Citation
Judgment date
December 1938
Whether a township management board owed a duty to fence an old gravel pit where a licensee fell while using a native track.
Township law – definition of "street" and footway; highway by dedication or prescription; occupier's duty to licensee limited to warning of concealed danger; Quarry (Fencing) Act – proximity requirement; Mining Proclamation inapplicability; Townships Regulations non-retrospective/permits only.
31 December 1938
The Credit Sales to Natives Ordinance renders non‑certified credit contracts unenforceable in Northern Rhodesia; lex fori governs enforcement.
Credit Sales to Natives Ordinance – statutory formalities – absence of District Officer’s certificate renders contract unenforceable (not void) in Northern Rhodesia – lex fori governs enforceability – Leroux v. Brown applied.
31 December 1938
Conviction under s.82(b) requires an inducement within the Territory; recruitment abroad precludes liability and conviction was quashed.
Employment of Natives Ordinance – s.82(a) and (b) – liability under s.82(b) requires prior inducement to proceed beyond the Territory – recruitment conducted abroad (outside Territory) precludes conviction under s.82.
31 December 1938
Subordinate Court III lacked jurisdiction to try murder; summary manslaughter convictions quashed and retrial ordered.
Criminal procedure — Subordinate Court (Class III) — lack of jurisdiction to try murder (s.7(2) Criminal Procedure Code) — improper summary adjudication under s.210 — excess of jurisdiction — proceedings null and void — convictions quashed — retrial ordered; irregularities in preliminary inquiry.
31 December 1938
Making false plates and riding in the stolen car made the respondent an accessory before the fact.
Theft — motor car — accessory before the fact — abetment by preparatory acts (selection, false number plates, participation) — presence at moment of removal not required — Penal Code s.21(b).
31 December 1938
Conviction for kidnapping upheld where servant lacked informed consent to removal beyond the Territory.
Criminal law – Kidnapping – Penal Code s.223 – Essential element: absence of informed consent to conveyance beyond Territory – Consent must be deliberate and informed – Silence or passive acquiescence insufficient – Evidence of assault beyond border admissible to explain continuous offence.
31 December 1938
A magistrate must state the charge and record the accused's plea before summarily adjudicating under section 210.
Criminal procedure — Preliminary inquiry — Amendment of charge from murder to manslaughter — Subordinate Court exercising s210 powers must state charge and call for plea per Part VI — Failure to record plea not necessarily fatal — No summary jurisdiction over manslaughter.
31 December 1938
Special finding of "guilty but insane" quashed where insanity at time of offence was not proved; conviction upheld and remitted for sentencing.
Criminal law – Insanity defence – Penal Code s.13 and McNaughton rules – Special finding "guilty but insane" – Indeterminate detention – Review quashing special finding for lack of proof at time of offence.
31 December 1938
Article 3(6) was directory and cannot sustain criminal convictions under Penal Code section 107.
Administrative law – Order in Council – Article 3(6) directory not penal – Criminal liability requires clear statutory basis – Penal Code s.107 (disobedience of statutory duty) inapplicable here – Public concern requirement for s.107 doubtful.
31 December 1938
Court reduced excessive aggregate imprisonment for multiple small-value thefts by a repeat offender to seven years six months.
Criminal law – Sentencing discretion – Multiple convictions – Concurrent and consecutive sentences – Reduction of excessive aggregate term for repeat offender.
31 December 1938
Article 3(6) of the Order in Council is directory, not a criminal provision; convictions under s.107 were quashed.
Administrative law – Crown Lands and Native Reserves (Tanganyika District) Order in Council 1929, Art 3(6) – directory not penal; Penal Code s.107 (disobedience of statutory duty) – inapplicable where duty is not criminal or matter of public concern; convictions quashed.
31 December 1938
Altering and tendering an out-of-date tax receipt as current constitutes uttering under Penal Code section 317, conviction upheld.
Penal Code s.317 – Uttering a document the operation of which has ceased by effluxion of time – Altered native tax receipt – False document – Appropriate charge versus forgery (s.316) or making alteration (s.312).
31 December 1938
A deportation warrant must contain a clear operative command specifying the period; mere recital of a recommendation is insufficient.
Deportation law – validity of deportation warrant – operative command must specify duration – recitals insufficient to prove period – Governor’s discretion over recommendations; form language ("warrant" v. "order") can cause confusion.
31 December 1938
A 12‑month hard‑labour sentence for an unplanned escape was deemed excessive and reduced to three months on review.
Criminal law – Escape from lawful custody (Penal Code s.101) – Sentence severity and proper punishment under s.40 – Unplanned escape by a person of low intelligence – Role of prison authority’s extramural employment – Reduction of sentence on review.
31 December 1938