High Court of Northern Rhodesia - 1940 December

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19 judgments
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Judgment date
December 1940
An inquest cannot be held without a body unless death is certain and the body destroyed or irrecoverable; the inquest was quashed.
Inquest law – requirement of a body – exception where body destroyed or irrecoverable (s.10) – ejusdem generis interpretation – need for clear evidence of death before inquest – quashing of inquest where death not established.
31 December 1940
A trustee may claim a bankrupt’s earnings above a reasonable maintenance allowance; court fixed a £42 monthly retention.
Bankruptcy Act 1914 s38 — trustee entitled to bankrupt’s future earnings; definition of "property" includes debts due from employer; maintenance allowance for bankrupt; trustee may intervene without prior notice or court order; Hill v. Settle and In re Graydon cited.
31 December 1940
A mine manager retains personal criminal responsibility unless he proves he took all reasonable measures; delegation alone is insufficient.
Mining law — Managerial responsibility — Regulations 10(1), 10(3), 10A(1)-(2) — "All reasonable means" — Delegation does not automatically relieve manager — Systemic failures attract liability; isolated lapses may not.
31 December 1940
A "guilty but insane" special verdict is an acquittal not revisable by the High Court, though it is appealable.
Criminal law — Special verdicts — "Guilty but insane" constitutes an acquittal — Revision excluded by section 309(1)(b) Criminal Procedure Code — Acquittals appealable under section 300(c) Criminal Procedure Code.
31 December 1940
Corporal punishment for adults is permissible only in recorded special circumstances; magistrates must state those reasons.
Corporal punishment — adults — only in special circumstances — Magistrate must record reasons — Instructions to Magistrates para 55 — Penal Code s.27 — caution against extending caning for adults.
31 December 1940
Sentencing must be guided by five principles—value of subject matter, antecedents, youth, plea, and local prevalence.
Sentencing principles — intrinsic value of subject matter; antecedents; youth; conduct at trial (plea); prevalence of crime; series of offences as single lapse.
31 December 1940
Compensation under s.164 CPC cannot be awarded in criminal proceedings for imputations of witchcraft that are essentially civil in nature.
Witchcraft Ordinance – imputation of witchcraft as criminal libel – spoken words not chargeable as defamation under Penal Code – limits on awarding compensation under s.164 Criminal Procedure Code – distinction between criminal remedy and civil remedies; native customary law not a ground for compensation in criminal proceedings where matter is essentially civil.
31 December 1940
Subordinate Courts may take similar outstanding charges into account at sentencing, subject to admission and procedural safeguards.
Criminal procedure — Consideration of outstanding charges in sentencing — Requirement of similarity and clear admission by accused — Prosecution consent if committal elsewhere — Applicability to Subordinate Courts under s.13.
31 December 1940
A child's out-of-court complaint to her mother is inadmissible unless the child testifies; medical evidence alone cannot support conviction.
Criminal law – Indecent assault – Admissibility of prior complaint evidence by mother when child does not testify – Such evidence is confirmatory, not proof – Medical evidence alone insufficient – Accused should not be called to defence when prosecution evidence insufficient.
31 December 1940
Keep-left regulation must be construed purposively; literal application improper absent other road users or potential danger.
Township regulations; Regulation 13 (keep left) – statutory interpretation – literal versus purposive construction – application only where actual or potential danger or other road users exist – limits to subordinate legislation’s scope (s.27(a)(8) Cap. 26/Cap. 120).
31 December 1940
Marginal notes and chapter headings do not impose a negligence requirement on offences under section 214; convictions upheld.
Statutory interpretation — Penal Code s214 construed as independent offence; marginal notes and chapter headings are not part of the statute and do not impose a negligence requirement.
31 December 1940
General deficiency alone does not prove embezzlement; reasonable doubt required, and acquittal cannot be overturned on revision.
Embezzlement — general deficiency insufficient alone; indictment should specify 'between' dates; reasonable doubt required for acquittal; High Court cannot overturn subordinate court acquittal on revision.
31 December 1940
Accomplice testimony requires independent corroboration; prior statements by a testifying witness were inadmissible, but convictions upheld.
Criminal law – accomplice evidence – requirement of independent corroboration – inadmissibility of prior statements by a testifying witness – duty of prison officers regarding escaped prisoners – harbouring and accessory after the fact.
31 December 1940
Accused charged with similar but unconnected offences should have been indicted separately, but no order made in absence of injustice.
Criminal procedure — Joinder of accused — Similar offences under same statutory provision — Offences unconnected to one another should be tried separately — No remedial order where no injustice resulted.
31 December 1940
A non-corporate firm cannot be convicted; individuals must be prosecuted and a manager's plea on its behalf is incompetent.
Non-corporate firm — no separate legal personality — cannot be charged or fined; manager's plea on firm's behalf incompetent; prosecute individuals instead.
31 December 1940
An uneducated accused must be clearly informed of the statutory age element and proviso before a guilty plea is accepted.
Criminal law – defilement – element of age in charge – necessity of explaining statutory age and proviso to an uneducated accused; judicial notice of different age-conception and use of non-year indicators (e.g., puberty) – plea equivocality – retrial ordered.
31 December 1940
A foreign decree nisi plus the respondent's admission can establish adultery and justify a decree nisi.
Divorce—adultery—proof by foreign decree nisi—respondent's written admission—Ruck v. Ruck; Little v. Little—combined evidence sufficient to establish adultery.
31 December 1940
Solicitor entitled to allowances for portions of travel days under Item 45, but not to detention allowances absent prior/subsequent detention.
Costs — Subordinate Court Rules Appendix D Item 45 (now Item 49) — travel and day allowances for portions of a day — detention requirement for second part of item — calculation of allowances.
31 December 1940
Money paid into court as security for a potential judgment belongs to the applicant, not the trustee in bankruptcy.
Bankruptcy – Trustee’s claim to funds – Money paid into court to abide event of judgment – Payment into court as security for successful creditor – Interim receiving order does not defeat plaintiff’s secured claim.
31 December 1940