Supreme Court of Zambia - 1981

20 judgments
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Results. 20 judgments found.

20 judgments
December 1981
A Government White Paper does not retroactively revoke an Establishment Circular; retrospective promotions are governed by the circular in force on the promotion date.
  • Administrative law; Civil service salary scales; Government White Paper as statement of intent not a revoking instrument; effect of retrospective promotion; conversion to new salary scales under Establishment Circulars
16 December 1981
An applicant alleging mala fides must prove it; mandamus refused where a statutory appeal exists.
  • Administrative law — Allegation of mala fides — Onus to prove mala fides lies on alleging party; Mandamus — discretionary remedy — refused where statutory appeal (s.16 Societies Act) available — reference to The People v Luanshya Municipal Council (ex parte Chendaeka)
16 December 1981
November 1981
False alibi not conclusive of guilt; spouse of a jointly indicted defendant is incompetent to testify against co-defendants; conviction quashed.
  • Evidence — Alibi: a false alibi is not necessarily conclusive of guilt; Evidence — Competency: spouse of one jointly indicted defendant is not competent witness against a co-defendant; Accomplice evidence and corroboration; Trial procedure — putting co-accused on defence
17 November 1981
October 1981
Insufficient chain of custody for fingerprint evidence transmitted by registered mail; conviction quashed.
  • Evidence — Fingerprint identification — Chain of custody essential — Where registered mail used, registered number/date and identifying marks must be specified to link posted and received exhibits
19 October 1981
Fairness in identification parades is essential; firearms parades are not mandatory; recent unexplained possession can support conviction.
  • Criminal procedure — Identification parades — fairness crucial; visible injuries give clues; suspects of comparable height and general dress suffice — Firearms parades not mandated — Alibi: prosecution’s onus to disprove — Unexplained recent possession and odd coincidences may support conviction
7 October 1981
Detention under public security regulations falls under Article 27; grounds must allow meaningful representation and alibi must cover the whole period.
  • Constitutional law — detention under Preservation of Public Security Regulations — detention as constitutional derogation governed by Art.27(1) not Art.15(3)(b) — sufficiency of grounds and vagueness — alibi must cover entire period alleged
7 October 1981
September 1981
Registrar and deputy/district registrars cannot make arrest orders under the Debtors Act; liberty matters reserved to judges in open court.
  • Civil procedure — Jurisdiction of Registrar — Construction of "the Court" and "a Judge" under High Court Rules (O.25 rr.1-2) — Registrar, Deputy Registrar and District Registrar possess powers of a judge in chambers (O.3 r.3) but are expressly excluded from matters relating to the liberty of the subject — Debtors Act s.10 orders for arrest and imprisonment out of Registrar's jurisdiction
14 September 1981
August 1981
Statements in a psychiatrist’s report are admissible only on mental state, not as evidence of guilt; conviction quashed.
  • Criminal evidence — admissibility of psychiatrist’s report — statements by the accused contained in medical reports inadmissible as evidence of guilt — psychiatric reports relevant only to mental condition — misdirection requiring reversal
10 August 1981
July 1981
Appellate court cannot order firearm forfeiture; prosecutorial request required under National Parks and Wildlife Act.
  • Forfeiture — Firearms Act s.54 (magistrate's discretion) — National Parks and Wildlife Act ss.77,138,145 (forfeiture only on Public Prosecutor's request) — appellate courts cannot make forfeiture orders — return of firearm and ammunition
27 July 1981
If evidence supports a more serious offence, the accused must be tried for it; appeals dismissed.
  • Criminal law and procedure — Elevation of charge where evidence warrants — Manslaughter versus murder — Accused's opportunity to dispute facts — Sentence review
27 July 1981
Recent possession and voluntary statements upheld convictions despite failure to warn a witness in possession; receivers' sentences reduced.
  • Criminal law — Recent possession doctrine; accomplice evidence — person in possession prima facie accomplice requiring warning and corroboration; voluntariness of confessions; statutory minimum sentence non-appealable; sentencing discretion for first offenders
22 July 1981
June 1981
Possession of a recently stolen vehicle may warrant conviction for receiving stolen property where theft is not the only reasonable inference.
  • Criminal law — Possession of recently stolen property — Inference of theft versus alternative explanations — Receiving stolen property — Admission of confessions and co-accused statements; proviso to section 15(1) Supreme Court Act
8 June 1981
May 1981
Previous convictions may reduce leniency but cannot justify a manifestly excessive sentence for minor theft.
  • Sentence review — Effect of previous convictions on leniency — Manifestly excessive sentence — Theft of low-value items
4 May 1981
March 1981
Court may review reasonableness of preventive detention; uncontradicted alibis can defeat detention under Article 26.
  • Constitutional law — preventive detention — Preservation of Public Security Regulations reg 33(1) — scope of habeas corpus — objective review of detaining authority's satisfaction — burden of proof under Article 26 — 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
Charge of murder/manslaughter must use date of death; a reasonably possible alternative cause creates reasonable doubt, so conviction overturned.
  • Criminal law — Murder/manslaughter — charge should state date of death; evidence — burden of proof — a 'reasonably possible' alternative causes reasonable doubt; evidence — accused’s lies may bolster credible evidence but cannot cure discredited or conflicting evidence
10 March 1981
Court adjusted the applicant's damages, addressing unconsciousness, special damages dating, multiplier choice and interest.
  • Damages — appellate interference with quantum; unconsciousness and its effect on pain and amenities; special damages calculated to date of trial; future loss assessed by combining actuarial and traditional methods; interest rates on damages
9 March 1981
Appellate court reversed misdirected factual findings, admitted negligence, and assessed damages for vehicle loss and personal injuries.
  • Evidence — motor-accident material evidence and disclosure; Pleadings — evidence not pleaded and proper objection/adjournment/recall procedure; Civil procedure — when appellate court may interfere with factual findings; Damages — assessment, loss of use of written-off vehicle, personal injury quantum
9 March 1981
February 1981
Immediate attempt to seize a weapon was grave provocation; applicant's belief of imminent danger could justify self-defence.
  • Criminal law — Murder — Provocation and loss of self-control — Immediate seizure attempt as grave provocation — Self-defence — Reasonable belief of imminent death or serious harm — Retreat considerations — Proportionality in the heat of the moment
17 February 1981
January 1981
An appellate court may enhance a sentence only if it is wrong in principle or totally inadequate; mere inclination is insufficient.
  • Sentence enhancement — Appellate court may only increase sentence if original sentence is wrong in principle or totally inadequate — Enhancement not justified by mere "inclination to enhance" — Kalunga v The People applied
5 January 1981