Supreme Court of Zambia - 1987

105 judgments

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105 judgments
Citation
Judgment date
December 1987
Whether "any person" in s.250(b) includes police officers; court holds it does not and substitutes conviction for common assault.
Criminal law – section 250(b) Penal Code – meaning of "any person" – does not include police officers; interaction between disciplinary provisions and criminal liability; substitution of conviction under Supreme Court Act s.15(3) and Criminal Procedure Code s.181(i); Interpretation Act s.41(i) on multiple statutes.
31 December 1987
Consent and trial judgments set aside due to mutual mistake about steel quantity and payment; retrial ordered.
Civil procedure – consent judgment – mutual mistake as to goods supplied and paid for – consent judgment set aside; appeal; trial judgment vitiated by same mistake – retrial ordered before different judge.
21 December 1987
Burden is on the landlord to prove a bona fide s.11(1)(g) intention; alternative accommodation is irrelevant.
Landlord and Tenant (Business Premises) Act – section 11(1)(g) – burden on landlord to prove genuine intention to occupy – availability of alternative accommodation irrelevant – question of fact and credibility – rehearing ordered.
20 December 1987
Court may order rectification under s.60, binding the company in litigation between the applicant and the respondent.
Companies Act s.60 – rectification of register – court may bind company in disputes between member and alleged member; shareholder supremacy – unanimous members' decisions validate defective directors' acts; sole shareholder powers to allot shares and appoint directors; wrongful transfer of company property – cancellation and account.
20 December 1987
Tenant estoppel upheld for rent claim; third party's ownership raises triable issue requiring remittal.
Landlord and tenant — denial of landlord's title by tenant — estoppel — summary judgment (Order 13) — third-party proprietary claim — triable issue — remittal for directions.
17 December 1987
Whether post-termination rent payments and conduct created a new tenancy and justified a stay of possession pending appeal.
Landlord and tenant law – Business Premises Act – whether post-termination payment and conduct can create a new tenancy – distinction from Bobert v Kapindula – stay of execution pending appeal – mesne profits.
17 December 1987
An adventurer is liable under s22 for co-conspirators' violence if it was a probable consequence of the common design.
Criminal law — Common unlawful purpose — Section 22 Penal Code — Liability for acts of co-conspirators that are a probable consequence of common design — Aggravated robbery where property is guarded — Distinguishing Mwape v The People.
13 December 1987
Conviction quashed for one appellant lacking proof of recent possession; other appellant's conviction and mandatory 15-year sentence upheld.
Criminal law – Aggravated robbery – Doctrine of recent possession – Recent possession as evidence of guilt – Sufficiency of evidence where accused merely found in premises where stolen property recovered – Mandatory minimum sentence – Appeal against conviction and sentence.
8 December 1987
Vendor cannot rescind or repossess without proper notice or evidence of purchaser's implied repudiation.
Conveyancing and Law of Property Act s.67; notice to complete; service by registered post; sale of land; rescission; implied repudiation; onus of proof.
8 December 1987
Recent possession supported the first appellant's conviction; mere presence where stolen property was found did not support the second's conviction.
Criminal law — Aggravated robbery — Recent possession as evidence of guilt — Presence in premises where stolen goods recovered insufficient without evidence of knowledge or control — Mandatory minimum sentence.
8 December 1987
Provocation can reduce murder to manslaughter where the trial judge wrongly dismisses its connection to the accused’s conduct.
Criminal law – murder v. manslaughter – provocation as partial defence – self‑defence – appellate substitution of conviction and sentence where provocation wrongly rejected.
8 December 1987
A properly served contractual notice to complete is required before a vendor may rescind; delay plus occupation/payment does not imply repudiation.
Land law – Contract to purchase land – Notice to complete – Service requirements – Time of the essence – Implied repudiation – Substantial payment and occupation negative repudiation.
7 December 1987
Whether a landlord’s genuine intention to reconstruct, supported by planning approvals, justifies opposing renewal of a business tenancy.
Landlord and Tenant (Business Premises) Act (Cap. 440) — s5 notice — s11(1)(f) reconstruction ground for opposing renewal — genuineness of landlord’s intention — relevance of planning permission and statutory approvals — inability to carry out works while tenant in occupation.
5 December 1987
November 1987
Seizure of an uncustomed, fraudulently documented vehicle upheld because the purchaser had notice and acquired no title.
Customs and Excise Act s.162 – seizure of uncustomed goods; Sale of Goods Act s.21(1) (nemo dat) and s.22 (market overt) – whether purchaser had notice; use of false customs/registration documents as constructive notice; fraudulently obtained goods – innocent purchaser doctrine; personal remedy against seller.
30 November 1987
Court grants a final 21-day extension to file appeal record and heads, refuses stay of possession, and requires security deposit or automatic dismissal.
Civil procedure – appeal – want of prosecution – final extension to file record and heads – automatic dismissal if conditions unmet; enforcement – refusal to stay possession order; security for judgment debt via jointly operated counsel account; costs against defaulting appellant.
24 November 1987
Applicants held liable for manslaughter under common purpose despite other villagers’ assaults; appeals against conviction and sentence dismissed.
Criminal law — Common criminal purpose — Joint adventurers and crimines participes — Causation where multiple assailants — Penal Code ss.207(d),(e) — Credibility findings on appeal — Manslaughter.
19 November 1987
Court upheld murder conviction, rejecting self-defence and finding witness corroboration sufficient; death sentence mandatory.
Criminal law – Murder – credibility and corroboration of witnesses – self‑defence rejected – independent corroboration by relative – mandatory death sentence.
19 November 1987
Conviction quashed where missing post‑mortem and unsafe in‑court identification rendered the murder charge unsupported.
Criminal law – murder – insufficiency of evidence where no post‑mortem produced – section 19(1) Criminal Procedure Code; identification evidence – requirement for identification parade; in‑court identification unsafe; unresolved evidential discrepancies; misdirection by trial judge.
18 November 1987
Participants in a joint assault are each liable for manslaughter if their cumulative conduct caused the victim's death.
Criminal law — Common criminal purpose — Joint adventurers and crimines participes — Cumulative assaults causing death — Attribution of fatal blow unnecessary; appellate review of credibility findings.
18 November 1987
Conviction based on an unadjudicated confession was unsustainable where voluntariness was not properly considered.
Criminal law – confession – voluntariness of statement – trial-within-a-trial – appellate review where accused alleges police brutality – circumstantial evidence and reliance on confession.
18 November 1987
Possession of recently stolen property did not prove aggravated robbery; conviction substituted for receiving stolen property.
Criminal law – aggravated robbery – sufficiency of evidence – possession of recently stolen property; inference of guilt not necessarily sole inference – receiving stolen property (s.318(1)) – substitution of conviction and sentence on appeal.
17 November 1987
The prosecution must prove a confession's voluntariness; misdirection on burden renders conviction unsafe.
Criminal evidence — confession — voluntariness — burden of proof rests on prosecution to prove voluntariness beyond reasonable doubt; misdirection on burden renders conviction unsafe.
17 November 1987
Appellants' aggravated robbery convictions upheld despite trial misdirections; appellate proviso applied owing to substantial corroborative evidence.
Criminal law — confession evidence — voluntariness — trial court misdirected by relying on contents of disputed statements; Identification evidence — conflict in witness accounts and pre-parade sighting; Appellate proviso — applied where ample corroborative evidence renders conviction safe; Convictions for aggravated robbery upheld.
15 November 1987
Presence at a robbery plus sale of stolen goods does not sustain aggravated robbery; conviction substituted to receiving stolen property.
Criminal law – Aggravated robbery – Sufficiency of evidence – Presence at offence and sale of stolen goods – Confession – Substitution of conviction to receiving stolen property (s.318(1) Penal Code) – Sentencing.
3 November 1987
Whether provocation (insults and assault) negated a murder conviction where appellant struck his father with a nearby hoe.
Criminal law – Provocation – Elements: act of provocation, actual and reasonable loss of self-control, proportionate retaliation; proportionality of retaliation where weapon at hand; appeal allowed and murder conviction/quashed and sentence reduced.
3 November 1987
Identification, recent possession and conduct sufficiently supported the aggravated robbery conviction; appeal dismissed.
Criminal law – aggravated robbery – identification evidence – recent possession of stolen property – corroboration – failure to explain possession – substitution of conviction – appellate review.
3 November 1987
Confessions improperly admitted; identification upheld; insufficient proof of firearm use—convictions reduced and 15-year sentences substituted.
Criminal law – confession statements – voluntariness – burden on prosecution to prove voluntariness; Identification – Turnbull principles – ample opportunity to observe; Evidence – proof of firearm – requirement of ballistic/forensic link to establish use of firearm; Substitution of conviction and sentence.
3 November 1987
Section 275 requires a prior conviction before a later offence can attract the enhanced mandatory minimum sentence.
Criminal law – Mandatory minimum sentence – section 275 Penal Code – Requirement of a prior conviction before commission of subsequent offence – Course of conduct versus second or subsequent offences – Untried outstanding charges not equivalent to prior conviction.
2 November 1987
October 1987
Court granted bail pending appeal after weighing sentence length, appeal prospects, applicant's bail conduct and personal standing.
Criminal procedure – Bail pending appeal – factors: length of sentence, prospects/merits of appeal, conduct on bail during trial, risk of interference, sureties, surrender of passport.
28 October 1987
Credibility findings and independent physical evidence supported conviction; accidental discharge and provocation defences rightly rejected.
Criminal law — murder — evaluation of eyewitness credibility — corroboration by physical evidence (cartridge cases) — accidental discharge versus deliberate shooting — rejection of provocation defence — appellate review of trial judge's factual findings.
20 October 1987
An acquittal without a verdict is a nullity; adjournment discretion must serve the broader interests of justice.
Criminal procedure — Adjournment — Prosecutor absent — Court's discretion must serve broader interests of justice; acquittal without a verdict is a nullity.
19 October 1987
Juvenile offender’s 15-year sentence set aside; three years' probation ordered under probation officer supervision.
Criminal law – Sentencing of juvenile offenders – Welfare report and time served – Substitution of custodial sentence with probation – Probation officer's supervisory discretion.
7 October 1987
Appellate court reduced a nine-year consecutive sentence to five years concurrent, balancing guilty-plea credit against systematic large-scale theft.
Criminal law — Sentencing — Theft by servant — Consecutive versus concurrent sentences — Credit for guilty plea and first-offender status balanced against systematic, large-scale theft — Appellate substitution of sentence.
7 October 1987
Appellant’s firearm-based aggravated robbery conviction quashed for lack of expert proof of a firearm; conviction substituted for use of an offensive weapon.
Criminal law – Aggravated robbery – Identification evidence and identification parade – Admissibility and reliability of eyewitnesses – Proof of firearm – necessity for expert evidence where firearm elevates offence to capital crime – Substitution of conviction and sentence.
6 October 1987
Court upheld first appellant’s murder conviction on corroborative admission; quashed second appellant’s conviction for lack of corroborated identification.
Criminal law – murder – identification evidence – reliability and need for corroboration of a witness who had been drinking and delayed reporting – corroboration by inculpatory admissions – application of proviso to save conviction.
6 October 1987
Trial misdirection rendered a false-information conviction unsafe; a separate repeat stock-theft sentence reduced to the mandatory seven years.
Criminal law – false information to public officer – public mischief – burden of proof – inadmissible requirement for independent corroboration of defence witnesses – misdirection – unsafe conviction. Criminal procedure – appellate review – proviso to s.15(1) Supreme Court of Zambia Act – when not to apply. Property crime – stock theft – subsequent offence – mandatory minimum sentence – appellate reduction where no aggravating circumstances.
6 October 1987
Trial within a trial required to decide voluntariness of statement; unwitnessed warn-and-caution statement can be admissible.
Criminal law – Confession and admissions – Voluntariness – Trial within a trial required where voluntariness or forced signing is alleged; warn-and-caution statements need not be witnessed to be admissible; sufficiency of evidence for murder conviction.
6 October 1987
Appeal allowed: provocation reduced murder to manslaughter where appellant used a knife immediately after being struck.
Criminal law – Provocation – Whether taking a weapon immediately at hand constitutes cooling-off – Reduction of murder to manslaughter; self-defence excluded; sentence for manslaughter involving a knife.
6 October 1987
Manslaughter is an inherent alternative to murder; conviction and five-year sentence were properly affirmed.
Criminal law – murder and manslaughter – lesser/alternative verdicts; requirement of plea; sentencing – first offender – appropriateness and absence of shock.
6 October 1987
September 1987
Qualified privilege succeeds if common interest exists and plaintiff fails to plead or prove express malice; unpleaded evidence inadmissible.
Civil procedure – pleadings and admissibility of evidence – necessity to plead all material facts; Defamation – qualified privilege – common interest – requirement to plead and prove express malice to defeat privilege.
21 September 1987
Court suspended a twelve-month theft sentence for two years due to mitigation and good character, conditional on no further dishonesty offences.
Criminal law – Theft – plea of guilty – abandonment of inconsistent grounds attacking conviction – sentence mitigation – suspension of sentence conditional on no further dishonesty offences.
15 September 1987
Award for undelivered equipment set aside; animal valuation to be reheard due to reliance on untested affidavit.
Civil procedure – assessment of damages – valuation of livestock – reliance on untested affidavit and failure to allow cross-examination – prejudice to respondent; Jurisdiction – award without counter-claim; Admissibility – execution of purported agreement (exhibit D1).
15 September 1987
Defective trial-within-trial and police officer’s theft rendered the applicants’ convictions unsafe.
Criminal law – admissibility of warned-and-cautioned statements – trial-within-a-trial – requirement to give adequate reasons – safety of convictions – evidence of police misconduct/planting of property – receiving stolen property.
15 September 1987
Conviction for burglary upheld; sentence increased on appeal was unjustified and substituted with five years' imprisonment.
Criminal law – burglary and theft – plea of guilty and admission of facts – appellate challenge to plea; Sentencing – appellate enhancement – reliance on prior convictions – improper and excessive sentence; mitigation for guilty plea and partial recovery of property.
15 September 1987
Identification corroborated by possession of stolen car, but recovered firearm not sufficiently linked to sustain firearm-enhanced conviction.
Criminal law – aggravated robbery – identity of accused corroborated by possession of stolen vehicle; recovered firearm not proved to be weapon used; failure to take fingerprints raises presumption favouring accused; requirement to prove firearm used capable of firing to sustain s.294(2) conviction; conviction substituted under s.294(1).
15 September 1987
Uncontroverted prosecution evidence upheld forgery conviction; appeals cannot reduce a statutorily prescribed mandatory sentence.
Criminal law — Forgery and uttering — sufficiency of prosecution evidence and effect of accused’s silence — photocopied certificate contradictions with school records; Criminal law — Aggravated robbery — mandatory minimum sentence — appeals against statutory sentences incompetent.
15 September 1987
Convictions based primarily on confessions admitted without adequate reasons, coupled with evidence of third-party possession, were unsafe and quashed.
Criminal law – aggravated robbery – admissibility of confessions – trial-within-a-trial – inadequate reasons – unsafe convictions; Recovery of stolen property at accused’s premises; Police officer’s possession and conviction relevant to safety of convictions.
15 September 1987
Appellate court reduced sentence from seven to four years after finding sentencing misdirection regarding irrelevant deterrence rationale.
Criminal law – manslaughter – sentencing – irrelevant considerations and misdirection by sentencing court – appellate interference and substitution of sentence.
15 September 1987
An appeal against a statute-prescribed mandatory 15-year sentence for aggravated robbery is incompetent and dismissed.
Criminal law – Aggravated robbery – Statutory mandatory minimum sentence of 15 years – Appeal against a sentence fixed by statute is incompetent – Juvenile exception noted.
15 September 1987
Appellate court quashed manslaughter conviction due to inconsistent evidence and a defective record supporting the accidental-collision defence.
Criminal law – manslaughter – sufficiency and consistency of evidence; causation of head injury (collision v. blow); appellate relief where record is defective; retrial discretionary.
15 September 1987