High Court of Northern Rhodesia

162 judgments
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Results. 162 judgments found.

162 judgments
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
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
December 1939
Court held Lord Campbell damages are pecuniary only; used income, dependancy share, and actuarial guidance to award £4,000.
  • Fatal Accidents Act 1846 (Lord Campbell’s Act) — damages limited to pecuniary loss — measure by portion of deceased’s income enjoyed by dependants — use of actuarial tables as a guide — insurance receipts and premiums treatment — allowance for remarriage and risky income.
31 December 1939
Shift-based pay and discretionary overtime are not "salary or income" under section 51(2); s.51(2) order refused.
  • Bankruptcy law — meaning of "salary or income" under s.51(2) — shift-based pay and discretionary overtime not salary — reliance on Ex parte Benwell, Ex parte Lloyd, Shine ex parte Shine, In re Landau.
31 December 1939
"Beyond the seas" means outside the territory; limitation runs after return, and service abroad risks the defendant if he absents himself.
  • Statute of limitations — meaning of "beyond the seas" — construed as "without the territories"; limitation runs only after return to territory; service abroad does not bar suit and, if duly served, a defendant who absents himself does so at his peril; jurisdiction may depend on submission.
31 December 1939
Application to read foreign-criminal-trial testimony in civil suit denied for lack of same parties/identity of issues.
  • Evidence — admissibility of prior testimony from foreign criminal proceedings — Order 37 rules — requirement of same parties or privies and identity of issues — adequacy of prior cross-examination — unavailable witness.
31 December 1939
Court shortened decree interval to allow the applicant and respondent to marry and legitimize the child.
  • Divorce procedure — shortening interval between decree nisi and decree absolute; legitimacy of child; public policy; distinction from expediting hearing; King's Proctor consenting.
31 December 1939
Mere failure to pay native tax is not evasion; evasion requires affirmative acts or attempts to deceive.
  • Native tax — evasion v. non-payment — evasion requires overt act or attempt to deceive (s14(1)(6)) — wilful neglect (s14(2)) only after statutory period — guilty plea recording (s187(2) CPC).
31 December 1939
Section 168 allows conviction only for offences included in the charge; unrelated offences cannot be substituted—conviction quashed.
  • Criminal Procedure Code s.168 — conviction for an included offence — "offence proved is included in offence charged" — cannot substitute conviction for an unrelated statutory offence; acquit and re-charge procedure.
31 December 1939
An accused’s admission and offer of money can sufficiently corroborate a child’s testimony to uphold an indecent-assault conviction.
  • Criminal law — Indecent assault on a child — Corroboration of child’s evidence — Admission by accused and offer of money as sufficient corroboration — Appellate review of magistrate’s credibility findings.
31 December 1939
Mere repetition of a witch-doctor’s diagnosis does not constitute an offence under the Witchcraft Ordinance; conviction quashed.
  • Witchcraft Ordinance — section 12 — requirement of an underlying offence to sustain conviction — imputing witchcraft — mere repetition/conveyance of a witch-doctor’s diagnosis not an offence — territorial jurisdiction (consultation outside Ordinance’s scope) — reliance on R v Nywelluna and R v Mpambani.
31 December 1939
Knowingly misleading police, causing unnecessary investigation and suspicion, constitutes common-law public mischief; conviction confirmed.
  • Criminal law — Public mischief (common-law misdemeanour) — Elements: misleading police causing wasted investigation; placing others at risk of suspicion or arrest — Conviction upheld.
31 December 1939
Permitting another to drive does not necessarily constitute an overt act "tending to serious risk" under section 75(1).
  • Employment of Natives Ordinance — section 75(1) — "doing an act tending to serious risk" — requirement of an overt act — breach of duty does not automatically constitute penal offence
31 December 1939
Under s.160(1) a magistrate must fix a definite reasonable costs amount and may not leave the sum unspecified or delegate its taxation.
  • Criminal Procedure Code s.160(1) — costs must be reasonable and for a definite amount — magistrates have no inherent jurisdiction — cannot delegate taxation or leave precise cost amount unspecified — order reviewed and set aside under s.309(1).
31 December 1939
Forfeiture of an accused's deposit is discretionary and should be postponed where a warrant is issued to secure appearance.
  • Criminal procedure — Forfeiture of recognizance/deposit — Discretion under s.124 — Forfeiture immediate if no enforcement steps; postpone if warrant issued — Right to show cause on appearance.
31 December 1939
Abduction conviction quashed where prosecution failed to prove the requisite element of secret confinement.
  • Criminal law — Penal Code s228 abduction — essential element: intent to secretly and wrongfully confine — plea-taking procedure — recording and construction of guilty pleas (CrPC s187(2)).
31 December 1939
Court approved child’s acquittal and clarified proper procedure and recording of pleas when altering charges and proceeding summarily.
  • Criminal procedure — alteration of charge during preliminary inquiry — summary determination under s210 Criminal Procedure Code — plea to be recorded in accused’s own words (s187(2)) — use of depositions and offer of witnesses for cross-examination (proviso to s210) — acquittal of a child under Penal Code provisions.
31 December 1939
A criminal court cannot determine wages after an employment contract has been terminated; the remedy is civil action.
  • Criminal procedure vs civil jurisdiction — employment contract terminated — magistrate lacked jurisdiction to determine wages — subsisting contract required for sections 72(1)(c) and 72(4) to apply — remedy is civil action for wrongful dismissal.
31 December 1939
Recent possession of stolen goods may sustain a receiving conviction but not necessarily a burglary conviction without proof of entry.
  • Theft/burglary — recent possession of stolen property — sufficiency of evidence for conviction under s271(2) Penal Code — receiving stolen property (s286(1)) — inconsistency of convicting for both burglary and receiving — substitution of conviction under Criminal Procedure Code.
31 December 1939
Causing annoyance to an individual is not a public nuisance; the proper charge is under Townships Regulations Reg. 4(9), not Penal Code s.151.
  • Criminal law — Common/public nuisance — Causing annoyance to an individual is not a common nuisance — Proper charge under Townships Regulations Reg. 4(9) — Misdescription of offence not fatal where no miscarriage of justice.
31 December 1939
A charge of noisy disorderly behaviour alleging annoyance to “any person” is fatally uncertain unless the annoyed person is specified.
  • Criminal law — Municipal by-law — Disorderly/noisy behaviour — Charge must specify the person annoyed; lack of particularity renders charge fatally uncertain.
31 December 1939
On an unequivocal guilty plea the magistrate must ordinarily convict and sentence forthwith; any departure requires recorded reasons.
  • Criminal procedure — Plea of guilty — Section 187(2) CPC — Mandatory conviction and sentence forthwith on unequivocal guilty plea — Trial after plea permissible only for quantum of sentence with recorded reasons — Examination of one or two witnesses may suffice.
31 December 1939
Conviction under s.158(3) quashed: antecedent reputation required for "suspected person"; mere circumstantial suspicion insufficient.
  • Criminal law — Rogue and vagabond — section 158(3) Penal Code — meaning of "suspected person" or "reputed thief" — antecedent reputation required — mere contemporaneous circumstantial suspicion insufficient; deportation recommendation not approvable for misdemeanour; procedural requirement to record judgment and sentence at conclusion of evidence.
31 December 1939
A joint trial was unfair where single counsel represented co-accused with conflicting defences and one accused was removed.
  • Criminal law — fair trial — conflict of interest where one counsel represents co-accused with antagonistic defences — removal of accused from courtroom without statutory authority — retrial ordered.
31 December 1939
A charge under section 273(1) should not separately cite section 243; the alleged felony must be specified in the particulars.
  • Criminal law — Penal Code s.273(1) — storebreaking and theft — correct form of charge — do not import s.243 into statement of offence; particulars must set out the alleged felony.
31 December 1939
Sleeping incapacity negates consent; penetration must be proved for rape, so conviction reduced to attempted rape.
  • Criminal law — Rape — Proof of penetration required for rape conviction — Consent — sleeping person incapable of consenting — Native custom should be proved by witness evidence not merely by assessors — Appeal — verdict unreasonable test and power to alter conviction to lesser offence.
31 December 1939
A court must record the specific offence of conviction; "Guilty" alone is inadequate.
  • Criminal procedure — Recording convictions — "Guilty" alone insufficient — Record must specify offence — Alternative convictions under Criminal Procedure Code s.171 (now s.174(1)(a)) must be stated and referenced.
31 December 1939