High Court of Northern Rhodesia - 1941

21 judgments
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21 judgments
Citation
Judgment date
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
A Governor's general order to continue work is not void for vagueness, but mere absence is insufficient—intention not to continue must be proven.
Emergency Powers (Defence) Regulations — Validity of Governor's Order — Order need not specify reasons or duration — Court may inquire into intra vires nature of Orders; Criminal law — Disobedience to Order to continue work — Mere absence insufficient proof of failure to continue work — Proof of intention or conduct required; Evidence — Necessity to prove fitness for duty and contractual terms when alleging breach of an order to continue work; Procedural fairness — No evidence that presiding Magistrate procured the Order.
31 December 1941
After a guilty plea, magistrates must secure the accused's agreement to the facts before sentencing; licence suspension requires an offence connected with driving.
Criminal procedure — plea of guilty — prosecution outline and accused's agreement — magistrate to be satisfied before sentence; Criminal Procedure Code s.273 — evidence after conviction for sentencing; Roads/vehicle regulations — construction/user offence — whether an "offence in connection with the driving of a motor car" permitting suspension of driving certificate.
31 December 1941
Court allowed immediate decree absolute where co-respondent's military service made future marriage impossible.
Divorce — shortening interval between decree nisi and decree absolute — wartime conditions and active military service — public policy — bona fides inquiries not required where irrelevant.
31 December 1941
Adultery proved but divorce dismissed—husband’s domicil remained Scotland; no domicil of choice in Northern Rhodesia.
Divorce — adultery proven; no connivance or condonation — domicile — change from domicil of origin to domicil of choice requires clear animus and factum; residence for employment insufficient; lack of jurisdiction.
31 December 1941
An accused cannot be convicted on witnesses called by the court after the defence closed unless the evidence arose ex improviso.
Criminal procedure – Court calling witnesses of its own motion under section 139 – Power limited to ex improviso evidence arising during trial – Conviction unsustainable where additional witnesses were procured after adjournment/investigation.
31 December 1941
A case stated must comply with section 320 and Form 20 of the Criminal Procedure Code; remitted for restatement.
Criminal procedure – Case stated – Form and procedure governed by section 320 and Form 20, Fourth Schedule, Criminal Procedure Code – Case remitted for restatement – Parties may draft proposed case for magistrate’s adoption.
31 December 1941