Supreme Court of Zambia - 1991

79 judgments
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Results. 79 judgments found.

79 judgments
December 1991
Court restrained removal of a vehicle pending trial where foreign seizure request lacked supporting evidence.
  • Civil procedure — Preservation of property — Order 27, Rule 3 — Interim injunction to prevent removal of property pending trial — Foreign seizure/Interpol request insufficient without evidence of foreign proceedings or judgment.
4 December 1991
Identification by mutual recognition and corroboration by possession of stolen property upheld; judge’s silence remark found immaterial.
  • Criminal law — identification evidence — reliability and mutual recognition; possession of stolen property as corroboration; adverse inference from accused’s silence; appellate review of misdirection.
3 December 1991
Proven refusal to live together and financial mismanagement can establish irretrievable breakdown; lengthy postponement of decree nisi was unjustified.
  • Family law — Divorce — Decree nisi — Irretrievable breakdown — Unreasonable behaviour — Refusal to live with spouse — Financial mismanagement — Judicial discretion in postponing decree for reconciliation.
3 December 1991
November 1991
A citizen’s constitutional right to travel includes a right to a passport, subject only to lawful, justified restrictions.
  • Constitutional law — Freedom of movement — Right to leave and enter the country — Right to issue of passports — Executive discretion to refuse or withdraw passports subject to constitutional and statutory limits — Withdrawal not justified by mere possession of a small quantity of cannabis — No statutory authority applicable
25 November 1991
The Supreme Court refused interlocutory bail, holding it lacks jurisdiction to entertain such applications during ongoing High Court trials.
  • Contempt of Court (Cap.53) — s.5 appeals in contempt — interlocutory appeals and bail — appellate jurisdiction — supervisory jurisdiction of Supreme Court — functus officio and trial judge’s power to revoke invalid committal orders.
21 November 1991
Failure to administer warn and caution rendered the police confession inadmissible, but res gestae and other evidence upheld the conviction.
  • Criminal law — Confession and caution — Failure to administer warn and caution raises presumption of involuntariness; admissibility of confessions — effect of defence counsel’s in-court disclosures; hearsay — res gestae exception for statements of deceased; safety of conviction absent police confession.
19 November 1991
Failure to administer warn and caution and defence counsel’s Bar disclosure rendered the police confession inadmissible, but other evidence upheld the conviction.
  • Criminal procedure — Confession — Failure to administer warn and caution raises rebuttable presumption of involuntariness; prosecution must explain. Defence counsel’s Bar statements about voluntariness may prejudice accused and breach duty of confidentiality. Res gestae and independent civilian admission admissible and can sustain conviction
18 November 1991
The appellant’s police-recorded confession improperly admitted was excluded, but conviction upheld on res gestae and civilian admission.
  • Criminal law — admissibility of confessions — failure to administer warn and caution raises rebuttable presumption of involuntariness; improper reliance on defence counsel’s bar remarks — confession excluded; res gestae and civilian admission admissible and sufficient to uphold conviction.
15 November 1991
Appeal dismissed: disciplinary demotion and pay stoppage of a public servant for failing to answer parliamentary question held lawful; no damages awarded.
  • Public service discipline — Parliamentary accountability — Failure to answer parliamentary question — Gross negligence of duty — Cabinet and Public Service Commission disciplinary action — Demotion and stoppage of pay — Lawfulness of sanctions and entitlement to damages.
9 November 1991
Accomplice testimony lacked adequate corroboration; conviction unsafe and quashed.
  • Criminal law — Murder — Accomplice testimony — Requirement of independent corroboration — Identification and circumstantial evidence — Shoe prints — Unsafe conviction where reasonable alternative hypothesis not excluded.
7 November 1991
Whether loss of employment resulted from localisation (Zambian takeover) or from contractual termination.
  • Labour law — displacement/localisation — causation — whether loss of employment resulted from a Zambian taking over the post or from valid contractual termination (payment in lieu of notice).
1 November 1991
October 1991
Unsubstantiated allegations of judicial bias in court can constitute contempt; conviction upheld but sentence reduced.
  • Contempt of court — Order 52 powers wider than s.116 Penal Code — Contempt in facie curiae — Unsubstantiated allegation of judicial bias as contempt — Judge may hold enquiry before whom contempt occurred — Sentencing limits and mitigation
21 October 1991
Oral contract for sale of land failed: insufficient memorandum, no part performance, no authorised agency; appeal dismissed with costs.
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3 October 1991
Recent possession of stolen vehicle can corroborate weak identification and sustain aggravated robbery convictions.
  • Criminal law — Aggravated robbery — Visual identification — Weak identification fortified by recent possession of stolen property as connecting link — Appellate review of findings of fact.
1 October 1991
September 1991
A book-entry transfer without formal assignment and registration does not pass legal title; the applicant obtained good title.
  • Property law — transfer by book-entry — requirement of formal assignment and registration under the Lands and Deeds Registry Act — book-entry alone does not pass legal title; purchaser obtaining registered title; caveat and possession; equitable considerations.
12 September 1991
Registered title obtained by innocent purchasers is indefeasible and defeats claims for possession and mesne profits absent fraud.
  • Land registration — Indefeasibility of title under Lands and Deed Registry Act (ss.54, 59) — Innocent purchaser for value — Registered title protects against claims for mesne profits/unjust enrichment absent fraud or error.
10 September 1991
August 1991
The appellant's challenge to identity and implication failed; daylight identification and sale of stolen goods upheld conviction.
  • Criminal law — aggravated robbery — identification in broad daylight — familiarity with accused — possession/sale of stolen property as corroboration — credibility findings — appeal dismissed.
6 August 1991
Recognition in broad daylight and recovery/sale of stolen property upheld a robbery conviction; appeal dismissed.
  • Criminal law — aggravated robbery — identification evidence — recognition of a known person in broad daylight — corroboration by recovery/identification of stolen property — appellate review of credibility findings.
6 August 1991
The appellant's mistaken-identity defence was rejected; identification, recovered property and pistols upheld the aggravated robbery conviction.
  • Criminal law — Aggravated robbery — Identification evidence and recovery of stolen property — Mistaken identity defence — Use of firearm — Compulsory minimum sentence — Appeal dismissed.
6 August 1991
July 1991
Accused who sought provocation and failed to prove diminished responsibility cannot avoid murder conviction; appeal dismissed.
  • Criminal law — Provocation — accused who induces or seeks provocation cannot rely on it; Diminished responsibility — burden on defence; no substantial impairment proved; Non-retrospectivity — s.12A Penal Code (Act 3 of 1990) not retrospective; Sentence — no extenuating circumstances, death sentence affirmed
31 July 1991
A plaintiff claiming damages for breach of a restraint of trade may also obtain an injunction under Order 27 Rule 4.
  • Contract law — restraint of trade — injunctions — Order 27 Rule 4 High Court Rules permits injunctions in suits restraining breach of contract even where damages are claimed; defendant's intention to breach raises a serious question to be tried; High Court jurisdiction to grant injunction affirmed.
30 July 1991
Whether justification defeats a libel claim where evidence shows title irregularities and alleged antecedent fraud.
  • Defamation — defence of justification — pleader’s role and permissible variation/development of pleadings; evidentiary challenge to title transfers and antecedent fraud; assessment of damages — publication, causation and remoteness.
26 July 1991
Court allowed variation of pleading to uphold justification based on title irregularities; damages award for libel upheld.
  • Defamation (libel) — justification defence — permissibility of variation/development of pleadings — challenge to title and irregularities in chain of title — causation and remoteness of damages — assessment of quantum.
26 July 1991
Appeal allowed where supporting police witnesses lacked credibility and corroboration, rendering manslaughter convictions unsafe.
  • Criminal law — manslaughter; credibility of prosecution witnesses; requirement of credible evidence before corroboration; corroboration and identification of assailants in custody-related deaths; unsafe conviction.
23 July 1991
Convictions quashed where key police witnesses lacked credibility and corroboration on timing and identity.
  • Criminal law — Credibility of prosecution witnesses — Corroboration — Identification — Unsafe convictions where key witnesses lack credibility and corroboration.
23 July 1991
Conviction for false pretences and unauthorized requisition upheld; 41-year custodial sentence quashed as grossly excessive and replaced with absolute discharge.
  • Criminal law — Obtaining pecuniary advantage by false pretences; making a document without authority — Sufficiency of evidence to sustain convictions — Sentencing: manifestly excessive sentence, proportionality, minor monetary value and refund as mitigating factors — Substitution of sentence with absolute discharge.
23 July 1991
Court dismissed challenge to parliamentary summons and related disciplinary consequences, holding Assembly acted within its statutory powers.
  • Parliamentary privileges — Power to summon witnesses — National Assembly (Powers and Privileges) Act (Cap. 17) — Sections 10, 14 and 19 — Civil servant’s duty to give evidence — Contempt — Vires review — Judicial non-interference with lawful parliamentary or employer action — Remedy against officers disrupting court proceedings.
16 July 1991
Counsel's in‑court consent to discharge an injunction binds the client absent a demonstrated mistake.
  • Civil procedure — Consent orders; Counsel's authority and agency — Statement by counsel in court that matter is settled binds client where no mistake between counsel and client — Lusaka West Development Co. v Turnkey Properties Ltd.
16 July 1991
Repeal of the one‑party provision revived fundamental rights; MPs who left UNIP may remain, and existing nominated MPs continue until dissolution.
  • Constitutional law — interpretation of "the Party" in transitional provision (art. 4A) — repeal of one‑party provision reviving fundamental rights — arts. 67(c) and 71(2)(b) discriminatory and ineffective — status of existing nominated MPs preserved until dissolution or revocation
10 July 1991
Following repeal of the one‑party provision, MPs who resigned UNIP may sit as independents; party‑membership conditions became discriminatory and ineffective.
  • Constitutional law — interpretation of "the Party" in transitional Article 4A — effect of repeal of one‑party Article on Articles 67(c) and 71(2)(b) — discrimination and fundamental rights — status of existing nominated members after repeal of Article 64 — eligibility of independents and barred new parties before dissolution
10 July 1991
Intoxication raised reasonable doubt on murderous intent; murder conviction quashed and substituted with manslaughter and seven-year sentence.
  • Criminal law — murder substituted with manslaughter — effect of intoxication on dolus — assessment of alleged witness bias (relatives of victim) — accidental discharge defence — appellate substitution of conviction and sentence.
9 July 1991
Appeal dismissed where eyewitness and ballistic evidence conclusively established the applicant's guilt; no appeal lies against mandatory death sentence.
  • Criminal law — Armed aggravated robbery — Use of firearm — Ballistic evidence — Eyewitness identification — Apprehension shortly after offence — Mandatory death sentence — Appealability.
9 July 1991
Intoxication raised reasonable doubt on intent; murder conviction substituted with manslaughter and seven-year sentence.
  • Criminal law — murder v. manslaughter — intoxication and mens rea — biased witnesses — res gestae — accidental discharge defence.
9 July 1991
The appellant’s conviction was quashed for factual misdirections and unresolved credibility conflicts concerning cheque transactions.
  • Criminal law — Theft by public servant — Credibility assessment and burden of proof — Misdirection on facts (cheque register maintenance, supporting vouchers) — Disputed cancelled cheque counterfoil — Proviso to s.15(1) not applicable.
7 July 1991
Wrong statutory citation did not invalidate measures; declared threatened emergency derogation ousted audi alteram partem.
  • Administrative law — incorrect statutory citation does not invalidate executive action if a valid enabling provision exists; natural justice — rebuttable presumption of audi alteram partem where livelihood or property affected, but article 26 derogation during declared emergency/threatened emergency can exclude prior hearing
4 July 1991
June 1991
Court refused to expand statutory class of dependants; lifetime assistance does not create a posthumous entitlement.
  • Succession—Inheritance (Family Provision) Act 1938—Definition of 'dependant'—High Court Act Cap.50 s.12 permits only verbal alterations, not substantive amendment—Lifetime assistance not creating posthumous entitlement—Equity (s.13) inapplicable to expand statutory classes
26 June 1991
Whether the appellant, as an employee of a statutory board, was disqualified from election under Article 65(5)(e).
  • Constitutional law — Article 65(5)(e) — disqualification from parliamentary election — meaning of "prescribed" and "under an Act of Parliament" — literal construction — employees of statutory boards not automatically disqualified unless office specifically prescribed by law
20 June 1991
Whether a statute fixing a widow's intestate share applies prospectively to estates administered after its commencement.
  • Intestate succession (customary law) — Statute fixing widow's share — Prospective operation of statute — Section preserving pre-existing rights (non-retrospectivity) — Procedure vs substantive rights — Remittal for hearing.
19 June 1991
The Intestate Succession Act operates prospectively; fixing a widow’s 20% share is procedural and may apply to future administration of earlier deaths.
  • Succession law — Intestate Succession Act No.5 of 1989 — Prospective operation — s.48 protects administrators’ and beneficiaries’ existing rights in respect of deaths before commencement — specification of widow’s quantum is procedural, not retrospective
18 June 1991
Appellant's murder conviction reduced to manslaughter for lack of proven malice aforethought; custodial sentence imposed.
  • Criminal law — murder v. manslaughter — malice aforethought — causation (blow to head) — common intention — sufficiency of eyewitness evidence — role of alleged confession.
12 June 1991
Appeal against alleged forfeiture dismissed; matter remitted for forfeiture proceedings and hearing of the appellant.
  • Criminal law — Forfeiture of property — No forfeiture order made or confirmed — Right of owner to be heard before forfeiture — Remittal to subordinate court.
11 June 1991
Granting leave to amend mid-trial requires permitting supporting evidence, subject to costs and adjournment.
  • Civil procedure — amendment of statement of claim at trial — re-opening plaintiff’s case to lead fresh evidence; interlocutory appeals — competent in civil matters; costs, adjournment and reciprocal amendment as safeguards.
11 June 1991
Counsel with ostensible authority who signs a consent summons binds the client; 'without prejudice' letters are generally inadmissible.
  • Civil procedure — consent summons; admissibility of 'without prejudice' correspondence; ostensible authority of counsel to bind client in settlement; withdrawal only for fraud or mistake
4 June 1991
May 1991
Whether a post-dated cheque constituted redemption; court limited interest to date of tender and ordered reimbursement for overpayments.
  • Mortgage redemption — Tender of payment — Obligation of mortgagee to disclose correct redemption figure — Interest chargeable only up to date of valid tender — Reimbursement with interest for overpayments — Inclusion of legal costs in redemption computation questioned.
31 May 1991
Inadequate voir dire rulings rendered co-accused confessions unreliable; first appellant's murder conviction reduced to manslaughter with seven-year sentence.
  • Criminal law — admissibility of confessional statements — adequacy of voir dire ruling; co-accused confessions not admissible against others; provocation as partial defence reducing murder to manslaughter; substitution of verdict and sentence.
31 May 1991
Bank lawfully refused payment per applicant's instruction; "payment stopped" not libellous; freezing personal cheques breached contract.
  • Banking law — stop-payment instructions — effect on post-dated cheques; Defamation — endorsement "payment stopped" not defamatory; Contract — unlawful freezing of accounts on head-office telex amounts to breach; Damages — need to plead and prove actual loss where accounts are frozen (Gibbons distinguished).
21 May 1991
Convictions based chiefly on a single identifying witness and improperly identified firearm were quashed for failure to warn and corroborate.
  • Criminal law — identification evidence — single identifying witness — trial judge must warn of dangers and seek corroboration; identification of a firearm must follow prescribed procedures; leading police to suspects or weapon insufficient alone for conviction.
7 May 1991
Appellants' aggravated robbery convictions quashed for misdirection and failure to consider exculpatory evidence.
  • Criminal law — aggravated robbery — use of violence — recent possession defence — misdirection by trial judge — failure to consider cross‑examination admissions and exculpatory statements — unsafe conviction.
7 May 1991
Court accepted psychiatric evidence of insanity, excluded a challenged confession, and ordered detention at the President’s pleasure.
  • Criminal procedure — Confession — voluntariness; trial-within-a-trial procedure; alleged pre-police force
  • Evidence — Expert medical evidence — psychiatrist may rely on clinical observations, patient history and other doctors’ notes
  • Criminal law — Defence of insanity — burden and evaluation; disposal by detention at President’s pleasure
  • Witness credibility — treating potentially interested witnesses with caution
5 May 1991
April 1991
Court allowed out-of-time appeal, set aside jurisdictional bar under Mutwale, granted respondent leave to defend and ordered trial.
  • Landlord and tenant — Order 13 summary possession — Jurisdictional challenge where lease lacked prior state consent (Mutwale) — Leave to appeal out of time — discretion to extend time — bona fides of delay — triable issues and right to defend.
23 April 1991