Supreme Court of Zambia - 1988

71 judgments
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Results. 71 judgments found.

71 judgments
December 1988
21 December 1988
Appeal allowed; costs award and threatened committal reversed where absence was caused by court's own notice.
  • Civil procedure — adjournment costs — absence of counsel due to court marshall's circular — contempt — threat of committal unjustified absent evidence of discourtesy — appellate discretion on costs.
7 December 1988
Court reduced pain-and-suffering award, ruling devaluation must be considered but not via simple multiplication.
  • Damages — Devaluation of the kwacha — Effect on awards; Pain and suffering — Appropriate weekly rate; Appellate interference — inordinately high awards
6 December 1988
Pinioning a victim's arms to prevent resistance constitutes 'violence' under aggravated robbery provisions; appeal dismissed.
  • Criminal law — Aggravated robbery — Meaning of 'violence' under s.294(1) Penal Code — Restraint/pinioning of arms suffices; beating not required — Identification in broad daylight.
6 December 1988
Appellate court upheld theft convictions where driver/recipient testimony and documentary irregularities corroborated each other.
  • Criminal law — Theft by public servant — Corroboration of accomplice and witness evidence by documents (missing invoices, audit) — Credibility findings — Appellate review of factual findings.
6 December 1988
Breach of Exchange Control Regulations did not constitute mala fides to bar setting aside a default judgment.
  • Civil procedure — Setting aside default judgment — Mala fides as bar to relief — Mala fides refers to conduct in the prosecution/defence of litigation, not unrelated breaches (eg Exchange Control Regulations) — Existence of bona fide defence and short delay justify setting aside default judgment
5 December 1988
An apex body's suspension of an affiliated union's officers is ultra vires absent express or necessarily implied disciplinary powers.
  • Trade union law — Disciplinary powers — Power to suspend or expel must be expressly provided or necessarily implied in rules — Statutory affiliation does not itself confer disciplinary authority on apex body — Ultra vires measures null and void
5 December 1988
November 1988
An appellate court may order concurrency to reduce an excessive aggregate sentence for offences forming one course of conduct.
  • Sentencing — cumulative consecutive terms — offences forming part of one course of conduct — appellate power to order concurrency to avoid an excessive aggregate sentence.
22 November 1988
Appeal against robbery convictions dismissed: identification parade evidence and recovered stolen property sufficiently proved the appellants' guilt.
  • Criminal law — Robbery — Identification evidence and identification parade — Recovery of stolen property as corroboration — Appeal against conviction — Sufficiency and evaluation of evidence.
10 November 1988
Appellate court upheld a ten-year hard labour sentence for manslaughter, finding deterrence and weapon use justified the sentence.
  • Criminal law — Manslaughter (provocation) — Sentence — Use of lethal weapon — Deterrence and exemplary punishment — Appeal against sentence — 10 years' imprisonment with hard labour upheld.
8 November 1988
October 1988
Identification alone at a night-time parade is unsafe; possession of recently stolen property can corroborate identification and sustain conviction.
  • Criminal law — aggravated robbery — admissibility of cautioned statements — adequacy of trial-within-a-trial ruling; Identification evidence — reliability of parade identification and requirement for corroboration; Possession of recently stolen property as corroboration of identification.
25 October 1988
Appeal allowed: murder conviction and death sentence substituted with manslaughter and three years’ imprisonment.
  • Criminal law — murder v manslaughter — parental corporal punishment resulting in death — necessity of proving intent to kill or cause grievous bodily harm — substitution of verdict and sentence on appeal.
17 October 1988
Contempt in view of the court must be dealt with summarily the same day or referred to the DPP.
  • Criminal procedure — Contempt of court — Penal Code s.116(2): contempt committed in view of the court must be dealt with summarily the same day; otherwise report to Director of Public Prosecutions — Judge’s committal powers (Order 52) and limited circumstances to act of own motion (Balogh)
11 October 1988
September 1988
Extension of time for probate registration; assessment and reduction of damages for pain and suffering post-kwacha devaluation.
  • Lands and Deeds Registry Act s5(3), s6 — extension of time for registration of probate; first proviso confers jurisdiction to extend time; second proviso limits voidness to land. Civil damages — personal injury; quantum for pain and suffering; effect of currency devaluation on assessment of general damages; reduction of excessive award
29 September 1988
Whether factor "C" in the statutory pension formula is computed as the actual excess of emoluments over K1,300, subject to a ceiling.
  • Pensions/statutory compensation — interpretation of statutory formula — meaning of factor "C" in section 53(3) — factor "C" is actual annual excess of emoluments over K1,300, subject to K3,040 ceiling.
29 September 1988
A State Advocate's alleged opposition to detention does not constitute fresh evidence for habeas corpus; appeal dismissed.
  • Habeas corpus — fresh evidence — allegation that State Advocate opposed continued detention — whether sufficient to reopen decided petition; State Advocate not detaining authority; remedy is representation to detaining authority.
21 September 1988
A no-case finding on the principal charge does not preclude conviction for a lesser offence if the evidence supports it.
  • Criminal law — no-case-to-answer (s291(2)) — conviction on lesser offence (s181(2)) — timing of operation of s181(2) — permissibility of convicting on lesser offence without calling accused to answer — contusions insufficient for grievous harm.
13 September 1988
Appeal allowed where sole eyewitness’s informed identification and alleged admission were unreliable, making the conviction unsafe.
  • Criminal law — aggravated robbery — identification evidence — witness reliability — trial judge misdirection — alleged admission to complainant — unsafe conviction.
13 September 1988
Where rent is payable in advance, unpaid rent is immediately in arrears; a deposit is not prepayment and eviction was lawful.
  • Landlord and tenant — Rent payable in advance — Meaning of "in arrears" under s.32A of Rent (Amendment) Act — Deposit not a pre‑payment of rent — Right of distress and replevin — Statutory eviction powers
5 September 1988
An apex trade union body cannot suspend an affiliate’s executive unless its rules expressly or necessarily imply such disciplinary power.
  • Trade union law — Powers of apex body over affiliates — Disciplinary powers (suspension/expulsion) must be expressly provided in constitution or necessarily implied — Mandatory affiliation does not alone confer such powers — Broad object clauses insufficient to create disciplinary authority
5 September 1988
State contractors’ failure to consult under statutory procedure rendered entry trespass; punitive damages set aside, additional compensatory damages awarded.
  • Property law — Trespass to land arising from state contractors taking gravel — Roads and Road Traffic Act s40 consultation requirement — Measure of damages for land damage (diminution in value vs cost of restoration) — Punitive damages must be specially pleaded; not available for bona fide public works improperly carried out.
3 September 1988
Uncorroborated but unchallenged oral evidence may establish value of lost goods; inconvenience damages not generally recoverable in detinue.
  • Detinue — wrongful detention of goods — assessment of damages — reliance on uncorroborated oral evidence for value where no other evidence available; special damages — desirability of documentary/independent proof for expenses but unchallenged lay evidence may be accepted; damages for inconvenience — not generally recoverable in detinue unless the tort itself directly causes the inconvenience.
1 September 1988
Consent judgments are confined to pleaded claims; affidavits for assessment cannot introduce new unpleaded heads of damages.
  • Civil procedure — Consent judgment — Scope limited to pleaded claim — Assessment of damages — Supporting affidavit cannot introduce new heads of claim — Registrar erred in awarding unpleaded damages; agreed items at assessment may be allowed.
1 September 1988
August 1988
Restricted publication and a late apology reduce defamation damages; 'contumelious' endorsement can plead exemplary damages.
  • Defamation — restricted publication and late apology as mitigating factors for quantum; exemplary damages sufficiently pleaded by 'contumelious' endorsement; servant personally liable where plaintiff sued servant alone; appellate reduction of excessive award
29 August 1988
Accused must be charged with armed robbery for death sentence; poor ID needs corroboration; unlifted fingerprints raise rebuttable presumption.
  • Criminal law — Disclosure of particulars: accused must be notified when charged with armed robbery; Identification evidence — in-court identification requires corroboration (e.g., recent possession); Fingerprints — failure to lift raises rebuttable presumption they are not the accused's; Sentencing — death sentence inappropriate where armed robbery not charged
24 August 1988
An injunction was inappropriate because the dispute was monetary and damages would adequately compensate the plaintiff.
  • Civil procedure — Interim injunction — Appropriateness where dispute is monetary — Balance of convenience only relevant if harm is irreparable and damages inadequate
24 August 1988
Conviction for obtaining money by false pretences upheld where evidence established deliberate misrepresentation despite weaknesses on related counts.
  • Criminal law — Obtaining money by false pretences — sufficiency of evidence — relevance of financial regulations on proof of identity — effect of acquittals on related counts on distinct conviction.
23 August 1988
Identification must be corroborated; possession of stolen goods can support conviction for receiving stolen property if armed-robbery identification fails.
  • Criminal law — armed robbery — identification at parade — corroboration by possession of recently stolen property — substitution of conviction for receiving stolen property — admissibility/weight of exhibits identified but not formally produced — sufficiency of firearm evidence for capital charge.
23 August 1988
Parties may validly contract to sell land conditionally upon obtaining Presidential consent under section 13(1).
  • Land law — Presidential consent — Validity of contracts for sale of land conditional on obtaining Presidential consent (Land (Conversion of Titles) Act, s.13(1)) — Summary judgment — Dismissal as frivolous and vexatious
17 August 1988
Failure to report contacts with alleged plotters, coupled with association, can justify preventive detention under public security law.
  • Constitutional law — Habeas corpus — Preventive detention under Preservation of Public Security Act — Failure to report contacts with alleged plotters — Relevance of criminal-law defences — Article 26 and judicial inquiry into reasonableness of detention
11 August 1988
Compensatory damages for assault and false imprisonment may include an exemplary element; interest adjusted for inflationary effects.
  • Damages — False imprisonment and assault — Compensatory award to include an exemplary element where conduct aggravated; quantum increased for inadequacy; inflation/devaluation to be considered in setting interest
10 August 1988
Employer's winding-up does not automatically curtail a deceased employee's future earning capacity for damages assessment.
  • Damages — Fatal Accidents — employer winding-up does not automatically negate future earning capacity; assessment by realistic multipliers; date of award governs kwacha valuation; interest on damages
10 August 1988
Conviction for aggravated robbery upheld; original 45-year sentence reduced to 25 years as excessive.
  • Criminal law — Aggravated robbery — identification evidence and corroboration — possession of proceeds — appellate review of sentence — excessive custodial term substituted.
9 August 1988
Aggravated robbery convictions quashed for lack of evidence and substituted with receiving stolen property convictions, each attracting five years' imprisonment.
  • Criminal law — Aggravated robbery — insufficiency of evidence to prove violence/threat — Convictions quashed — Substitution with offences of receiving stolen property (s.118 Penal Code) — Sentencing to concurrent five years' imprisonment with hard labour.
9 August 1988
July 1988
Court reduced a seven-year manslaughter sentence to 18 months, prioritising guilty plea and first-offender mitigation.
  • Criminal law — Sentencing — Manslaughter involving a mentally ill victim — Mitigation: guilty plea and first-offender status — Deterrence against assaults on mentally ill persons — Reduction of sentence.
26 July 1988
President's proscription under s53 valid; Gazette publication mandatory, local newspaper publication directory; appeal dismissed.
  • Penal Code s53(1) — proscription of publications — statutory interpretation of 'and' — mandatory Gazette publication vs directory local newspaper publication — public interest definition (s62) — Standing Orders and petition procedure — judicial review of presidential discretion: bad faith/improper motive/unreasonable view.
23 July 1988
June 1988
Convictions for aggravated robbery upheld despite suspect witnesses; the first appellant's consecutive 30-year sentence reduced to concurrent 18-year terms.
  • Criminal law — aggravated robbery — suspect witnesses and corroboration — value of independent positions of witnesses — identification evidence — "something more" (coincidence/furtive discovery) — admissions to police — sentencing: excessive cumulative/consecutive sentences set aside; mandatory minimum sentence not attackable on appeal.
14 June 1988
Time stipulated as essential is not waived by an extension; a defaulting purchaser cannot obtain specific performance.
  • Contract law — Sale of land — Time of the essence — Special condition fixing completion within 30 days of State consent — Extension of time substitutes rather than waives requirement — Defaulting purchaser not entitled to specific performance.
13 June 1988
Detention under public security regulations upheld; served grounds sufficient and no extra damages for non‑discriminatory poor conditions.
  • Preservation of Public Security — detention for sheltering alleged escapee — sufficiency and intelligibility of grounds of detention — limits on going behind served grounds — vagueness standard — damages for detention conditions require deliberate/discriminatory breach or alternative remedy absent
12 June 1988
Detention under public security regulations was reasonable, grounds adequate, and the appeal dismissed.
  • Preservation of Public Security — detention under regulations — Article 26 reasonableness inquiry — sufficiency and clarity of grounds (Article 27) — impossibility test for unlawful detention (Chisata principle)
12 June 1988
May 1988
Court set aside consent judgment to allow amendment of writ where an obvious mistake demanded correction, with costs and timetable directions.
  • Civil procedure — Amendment of specially endorsed writ after consent judgment — Setting aside consent judgment and assessment for obvious mistake — Finality of litigation versus interests of justice — Costs and timetable for re-opened proceedings.
31 May 1988
Identification and recovery evidence upheld convictions; court could not reduce the mandatory minimum sentence imposed on the appellants.
  • Criminal law — Aggravated robbery — Identification evidence — Recovery of stolen property — Corroboration — Sufficiency of violence — Mandatory minimum sentence — Appeal dismissed.
9 May 1988
Appellate court set aside sentence where sentencing courts misapprehended facts and drew unsupported inferences.
  • Criminal law — Possession of firearm and ammunition without licence — Sentencing — Misapprehension of facts by sentencing court — No evidence of intent to poach or inability to handle weapon — Sentence set aside.
9 May 1988
Tearing up a trust deed does not transfer beneficial ownership; nominees cannot mount a just-and-equitable winding-up against the beneficiary.
  • Company law — Beneficial ownership v registered ownership — Whether destruction of trust deed effects transfer — Appropriateness of deciding beneficial ownership in winding-up petitions — Presumption of undue influence where fiduciaries receive unexplained gifts
8 May 1988
Alleged omissions in the trial record failed to overturn conviction based on credible identification; mandatory sentence unappealable.
  • Criminal law — Aggravated robbery — Identification and credibility of witnesses — Appeal on ground of alleged omission from trial record — Presumption that court acts are done regularly — Mandatory minimum sentence unappealable.
5 May 1988
Court upheld aggravated robbery conviction based on recognition identification, recent possession, and corroborative arrest evidence.
  • Criminal law — Aggravated robbery — Identification evidence and opportunity to observe — Fairness of identification parade — Recent possession and corroboration — Non-production of alleged exhibit — Trial judge’s alleged misdirection.
3 May 1988
April 1988
Complete breakdown of trust and effective exclusion from management justified winding up; arbitration was futile.
  • Company law — quasi‑partnership/joint venture — deadlock and loss of mutual trust — just and equitable winding‑up; arbitration clause not decisive where arbitration would be futile; remedies and clean hands considered
20 April 1988
Presence in a joint store-breaking does not prove common intent to murder; uncontradicted mitigating confession matters must be considered.
  • Criminal law — Murder — Joint enterprise/common purpose — Presence in a group not automatically proof of intent to kill; Confession admissibility — trial-within-a-trial; Mitigating assertions in confession to be weighed if uncontradicted; Substitution of conviction for lesser offence (store breaking).
19 April 1988
Appeal dismissed: mere dissatisfaction is not a ground and eyewitness identification upheld the aggravated robbery conviction.
  • Criminal law — Aggravated robbery; eyewitness identification; adequacy of grounds of appeal — mere dissatisfaction inadequate; trial judge's directions; statutory minimum sentence.
19 April 1988
Second appellant’s conviction unsafe and quashed; first appellant’s conviction upheld but sentence reduced to mandatory minimum.
  • Criminal law — Aggravated robbery — Identification and reliability of witnesses — Possession and recovery of stolen property as corroboration — Sentencing — Mandatory minimum term — Improper reliance on prevalence of offences to increase sentence — Gang participation as aggravating factor.
19 April 1988