Supreme Court of Zambia - 1981

20 judgments

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20 judgments
Citation
Judgment date
December 1981
A Government White Paper cannot itself revoke an establishment circular; retrospective promotions are governed by the circular in force on the promotion date.
Administrative law; Civil service; Government White Paper cannot itself revoke an Establishment Circular; retrospective promotion governed by circulars in force on effective date; salary conversion under new scales.
16 December 1981
Allegation of mala fides must be proved; mandamus refused where statutory appeal to the Minister under Societies Act is available.
Civil procedure – Mandamus – Court’s discretion to refuse mandamus where statutory appeal exists; Societies Act s.16 – appeal to Minister – Mala fides – Allegation requires proof; burden of proof on alleging party.
16 December 1981
November 1981
A false alibi is not conclusive; a defendant's spouse is not a competent witness against a co-defendant in a joint trial.
Evidence – Alibi: a false alibi is not necessarily conclusive of guilt; Evidence – Competency of witnesses: spouse of a jointly indicted defendant is not competent witness against co-defendant; Accomplice evidence requires proper corroboration; Criminal procedure – co-accused should be put on defence when implicated by possession of stolen property.
17 November 1981
October 1981
Conviction unsafe where prosecution failed to establish chain of custody for fingerprint evidence sent by registered mail.
Evidence – Fingerprint identification – Chain of custody – Registered mail – Necessity to prove registered number, date and identifying marks of postal packet – Requirement to identify specific exhibit lifted from scene.
19 October 1981
Whether identification parade fairness, firearms identification, and disproving alibi suffice to support conviction.
Criminal law — Identification parades: fairness requirements where suspects have visible injuries or differing heights; firearms identification parades not mandatory but preferable in proper cases; prosecution's duty to disprove alibi; unexplained recent possession and odd coincidences may corroborate identification.
7 October 1981
Whether administrative detention for public security is governed by Article 27(1) (not Article 15(3)(b)) and requires comprehensive alibi evidence.
Constitutional law – administrative detention under Preservation of Public Security Regulations – applicability of Art.15(3)(b) v. Art.27(1); sufficiency of grounds for detention; alibi must cover entire period alleged
7 October 1981
September 1981
A Registrar has judge-in-chambers powers but cannot order arrest under the Debtors Act; liberty matters are excluded.
Civil procedure — Jurisdiction of Registrar, Deputy Registrar and District Registrar — Construction of "the Court" and "a Judge" under High Court Rules (O.25 rr.1–2) — Registrar's powers under O.3 r.3 — Exclusion of matters relating to liberty of the subject (O.3 r.3(a)) — Debtors Act s.10 (arrest and imprisonment).
14 September 1981
August 1981
A psychiatrist's report containing the accused's statement cannot be used to prove guilt; such reliance is a serious misdirection.
Evidence — Psychiatrist's report — Statement of accused recorded in psychiatric report — Report relevant only to mental condition and not admissible as evidence of guilt — Reliance on such statement by trial judge a serious misdirection — Proviso to s.15(1) Supreme Court Act not applicable where remaining evidence not overwhelming.
10 August 1981
July 1981
Forfeiture orders set aside; s.145 NPW Act permits forfeiture only on trial prosecutor's request, not on appeal.
Forfeiture — Firearms and ammunition — Firearms Act s.54 (magistrate's discretion) — National Parks and Wildlife Act s.145 (forfeiture only on Public Prosecutor's request) — Forfeiture cannot be imposed on appeal — Return of property ordered.
27 July 1981
Where evidence supports a more serious offence, the accused must be tried for it; manslaughter here should have been murder.
Criminal procedure – Charging – Where evidence supports a more serious offence accused must be tried for that offence; manslaughter charges may be inappropriate where facts warrant murder.
27 July 1981
Recent possession supports conviction; courts must warn when a possessor of stolen property may be an accomplice.
Criminal law – recent possession doctrine; possession of stolen property prima facie indicates accomplice status; caution required when relying on possessor's evidence; voluntariness of statements; application of proviso to sustain convictions.
22 July 1981
June 1981
Possession of recently stolen property requires consideration of theft inference and may justify conviction for receiving if theft is not proved.
Criminal law – Possession of recently stolen property – Inference of theft – Duty to consider alternative explanations – Misjoinder/misdirection and proviso – Substitution of conviction to receiving stolen property.
8 June 1981
May 1981
Prior convictions may reduce leniency but cannot justify a sentence disproportionate to the offence.
Sentence - Previous convictions - Effect on leniency; Sentencing proportionality - value of property; Excessive sentence substituted on appeal.
4 May 1981
March 1981
Court held emergency detention subject to objective reasonableness review; detainee must show measures were unreasonable.
Constitutional law – detention under emergency regulations – Preservation of Public Security Regulations reg.33(1) – reviewability of detaining authority’s satisfaction – objective reasonableness test – burden on detainee under Article 26 – habeas corpus and uncontradicted alibi evidence.
25 March 1981
Failure to disclose material accident evidence may warrant adjournment; appellate court can reassess credibility and award damages.
Motor-vehicle accidents — disclosure of material evidence and adjournment — unpleaded defence at trial — immediate objection, amendment or recall — appellate interference with credibility findings — assessment of damages where appeal likely — loss of use and quantum for minor personal injuries.
11 March 1981
In murder/manslaughter, the date of death must be charged; a reasonably possible alternative causation creates reasonable doubt.
Criminal procedure — murder/manslaughter: charge date should be date of death; Evidence — 'reasonably possible' alternative creates reasonable doubt; Accused's lies — may bolster credible evidence but cannot make unreliable evidence reliable.
10 March 1981
Appeal allowed; appellate standards for quantum applied, unconsciousness limits felt suffering but not loss of amenities, and future loss capitalised using corrected multiplicand and multiplier.
Damages — appellate interference with quantum; unconsciousness — effect on pain and amenities; special damages — computed to trial date; future loss — conventional vs actuarial methods; multiplier and multiplicand; interest rates on damages.
9 March 1981
Court held defendant negligent; material undisclosed evidence should prompt adjournment and damages assessed on appeal.
Evidence - material disclosure and adjournment in motor accidents; pleadings - effect of unpleaded evidence and immediate objection; appellate interference with factual findings; assessment of damages including loss of use and personal injuries.
9 March 1981
February 1981
Immediate attempt to seize a weapon can be grave provocation; self‑defence may justify lethal force in the heat of the moment.
Criminal law – Murder – Provocation and self‑defence – Immediate attempt to seize weapon as grave provocation – Imminent danger and reasonable belief of assault – Heat‑of‑moment proportionality.
17 February 1981
January 1981
An appellate court may enhance sentence only if it is wrong in principle or totally inadequate; mere inclination is insufficient.
Sentence — Enhancement of sentence by appellate court; appellate interference only if sentence wrong in principle or totally inadequate; mere 'inclination to enhance' insufficient; Kalunga v The People applied.
5 January 1981