Supreme Court of Zambia - 1990

21 judgments

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21 judgments
Citation
Judgment date
October 1990
Appeal dismissed: identification and witness credibility upheld despite minor inconsistencies; conviction for aggravated robbery affirmed.
Criminal law – Aggravated robbery – Identification evidence – Witness credibility – Darkness and vegetation – Alleged inconsistencies not amounting to material contradictions – Appeal dismissed.
25 October 1990
Administrator General negligent for failing to pursue estate claim (devastavit); damages limited to loss of expectation of life (K3,500).
Damages; Negligence by Administrator General; Devastavit by delay; Limitation of actions; Administrator General's Act s.30 not available if not pleaded; Measure of damages under Law Reform (Miscellaneous Provisions) Act; Interest and costs.
22 October 1990
September 1990
Interlocutory injunction restoring employment is exceptional; damages usually adequate unless irreparable injury shown.
Injunctions — interlocutory relief in wrongful-dismissal cases — adequacy of damages vs irreparable harm — reinstatement rare and requires probability of entitlement.
26 September 1990
Appeal allowed: wrongful eviction claim not barred by res judicata; matter remitted for trial and costs to follow.
Civil procedure — Res judicata — Wrongful eviction claim not barred where it was never tried; misleading pleadings may still disclose viable causes of action; remittal to trial court — Abuse of process — Re-litigation of unresolved issues not abusive.
13 September 1990
Appellate court increased damages for serious temporary injuries, accepted unchallenged taxi earnings evidence, and awarded interest.
Damages — appellate interference with quantum — standards for reversal; adequacy of general damages for non‑permanent but serious injury; proof of special damages — acceptance of unchallenged viva voce evidence where documentary proof unlikely; mitigation of loss; interest on assessed damages.
10 September 1990
Default judgment obtained under a defective writ set aside; respondent must repay amounts and bear appellant's costs.
Civil procedure — Defective writ/incorrectly entitled and served writ — Default judgment set aside — Repayment of sums paid under set-aside judgment — Leave to amend writ — Costs awarded against respondent.
4 September 1990
August 1990
Recent possession or sale of stolen goods alone cannot sustain aggravated robbery; convictions substituted for receiving stolen property.
Criminal law – Aggravated robbery – Insufficient evidence where only proof is sale/possession of stolen goods – Recent possession does not alone establish participation in robbery – Substitution of conviction to receiving stolen property – Sentence imposed.
14 August 1990
July 1990
Court set aside eight‑year sentence imposed under mistaken belief mandatory minimums applied; re‑sentencing required.
Criminal law — Stock theft — Sentencing — Mandatory minimum sentences (Act No.2 of 1987) not retrospective — Sentencing judge’s error — Number of animals relevant but not determinative.
25 July 1990
June 1990
Conviction unsafe where key witnesses had an interest and their mutual testimony lacked independent corroboration.
Criminal law – Corroboration; witnesses with interest to serve (detention/failure to report); limitations on mutual corroboration of suspect witnesses; requirement of independent corroborative evidence.
18 June 1990
Supreme Court cannot grant bail unless an appeal to it has been properly lodged under sections 12 or 14.
Criminal procedure – Bail – Jurisdiction of the Supreme Court – Order 27 – Section 22 Supreme Court Act – Appeals under sections 12 and 14 required – Prior decisions per incuriam.
17 June 1990
Court refused late filing of answer; delay self‑inflicted, counsel’s affidavit inadequate, appeal dismissed with costs.
Civil procedure – extension of time – application to file answer out of time – need for satisfactory explanation and absence of self‑inflicted delay; admissibility and weight of affidavits sworn by counsel; public policy against reopening finalized divorce proceedings.
15 June 1990
Consent orders signed by counsel with ostensible authority cannot be withdrawn absent fraud or mistake.
Civil procedure – Consent judgments – "Without prejudice" communications generally inadmissible but exceptions where necessary; counsel's ostensible authority to conclude settlements; internal undisclosed corporate limits cannot impeach valid consent; withdrawal of consent only on vitiating grounds (fraud/mistake).
4 June 1990
May 1990
Suspending a one‑year tail of a six‑year term for five years unlawful under section 16; sentence reduced and backdated.
Criminal law – Sentencing – Suspension of sentence – Section 16 Criminal Procedure Code – suspension period limit; improper suspension of small tail-end portion – sentencing credit for time in custody – inconsistency in accepting prosecution facts for conviction but rejecting them at sentencing.
21 May 1990
March 1990
Dismissal for non-attendance was set aside: appropriate remedy is strike-out with restoration, matter remitted for merits consideration.
Civil procedure — non-attendance at hearing — striking out vs dismissal — restoration application — procedural fairness in handling applications for leave to appeal from deputy registrar’s summary judgment.
2 March 1990
February 1990
Court reduced an excessive personal‑injury award and set K300/week guideline for pain and suffering conversion.
Damages – personal injury – near total loss of use of a limb – conversion of foreign awards to kwacha – realistic approach to exchange rate and inflation – guideline K300/week for pain and suffering – appellate reduction of excessive award.
28 February 1990
Whether published allegations of drug trafficking referred to the applicant and whether privilege or fair comment defended the respondent.
Defamation – Libel – Identification by name and particulars – Whether words capable of referring to the plaintiff; Qualified privilege – fair and accurate reporting – failure to produce trial transcript; Fair comment – failure to prove factual basis; Assessment of compensatory damages for imputations of criminality.
27 February 1990
Whether published defamatory words referred to the plaintiff and who bears the onus to prove reference in libel.
Defamation (libel) – Reference and identification – Onus on plaintiff to prove publication was of and concerning him – Qualified privilege and fair comment must be established by evidence.
27 February 1990
In high‑rise multi‑occupation, landlords owe a duty to reasonably maintain common access, not an absolute guarantee of constant service.
Landlord and tenant — implied covenant to maintain common parts in high‑rise buildings; duty to take reasonable care to repair and maintain lifts and stairs; no absolute warranty of constant availability; covenant of quiet enjoyment requires active interference to be breached; liability may rest with specialist contractors if negligent.
18 February 1990
Appeal allowed: murder conviction reduced to manslaughter where trial judge failed to address affray/self‑defence allegation.
Criminal law – murder v. manslaughter – provocation and self-defence (affray) – appellate review where trial judge omits to address material defence – doubt resolved for accused – sentencing for serious manslaughter.
7 February 1990
Convictions for fraudulent misapplication of service property quashed where materials were properly authorized and no intent to permanently deprive proved.
Criminal law — Fraudulent misapplication of service property — Sufficiency of evidence — Authorization of procurement for government house repairs — Intention to permanently deprive — DPP discontinues support — Convictions quashed.
7 February 1990
January 1990
Damages for inconvenience are recoverable in breach of contract, but a periodic award for alternative transport was set aside where title failed to pass.
Contract — Sale of goods — Failure to pass good title — Remedies: refund of purchase price with interest and reimbursement of expenses; damages for inconvenience recoverable in breach of contract; periodic award for alternative transport set aside where inappropriate given total failure of consideration.
7 January 1990