Supreme Court of Zambia - 1991

79 judgments
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Results. 79 judgments found.

79 judgments
April 1991
Appellate court allowed appeal against aggravated robbery, substituted conviction for receiving stolen property and imposed seven years' imprisonment.
  • Criminal law — sufficiency of evidence — identification and recent possession — receiving stolen property as alternative to robbery — benefit of the doubt where prosecution fails to eliminate innocent explanation.
18 April 1991
Appellate court upheld dangerous driving conviction where magistrate credibly found appellant drove a tractor without lights at night.
  • Criminal law — Dangerous driving — Driving an unlit vehicle at night — Credibility findings by trial court — Scope of appellate review — Subsequent use of vehicle does not necessarily rebut evidence of condition at time of accident.
16 April 1991
Uncertain identification upheld by appellant's confession and possession of stolen property, sustaining conviction for aggravated robbery.
  • Criminal law — Identification — Probative value of uncertain witness identification corroborated by confession and possession of recently stolen property — Admissibility and weight of discovery evidence.
16 April 1991
Murder conviction reduced to manslaughter due to doubt about intent despite sufficient medical evidence of causation.
  • Criminal law — murder v. manslaughter — mens rea (intention to kill or cause grievous bodily harm) — causation and medical treatment under s207(a) Penal Code — appellate substitution of conviction and sentence.
3 April 1991
March 1991
Conviction for aggravated robbery affirmed; sentence reduced to the mandatory minimum of 15 years imprisonment.
  • Criminal law — aggravated robbery — sufficiency of evidence and identification; sentence — minimum/mandatory sentence; appellate review of sentence.
15 March 1991
Conviction for causing death by dangerous driving upheld; sentence reduced for excess despite child's contributory negligence.
  • Criminal law — Causing death by dangerous driving — Objective test of fault — Foreseeability of pedestrians' conduct (children) — Contributory negligence relevant to sentence but not automatic exculpation — Sentence reviewed for excessiveness.
12 March 1991
Uncorroborated evidence and an improper inference from silence warranted quashing convictions and acquittal of the appellants.
  • Criminal law — Aggravated robbery; corroboration of accomplice/purchaser evidence; reliability of witness; failure to call police/vigilantes; inadmissible adverse inference from accused's silence.
6 March 1991
Knowledge of stolen property’s whereabouts alone cannot sustain a conviction for aggravated robbery.
  • Criminal law — Aggravated robbery — Knowledge of location of stolen property and directing police thereto — Mere knowledge/association insufficient to prove guilt beyond reasonable doubt.
5 March 1991
The applicant's on-scene apology was accepted as an admission supporting conviction for aggravated robbery.
  • Criminal law — Aggravated robbery — Elements: assault with weapon and theft — Evidence — Admission/apology to complainant as evidence — Credibility findings of trial judge — Appellate review of credibility and misdirection.
5 March 1991
Challenges to identity and common intention rejected; conviction and mandatory 15-year sentence upheld.
  • Criminal law — Aggravated robbery — Identification evidence and credibility — Common intention — Appeal against conviction and mandatory minimum sentence.
5 March 1991
February 1991
Whether eyewitness and recovery evidence sufficiently corroborated to safely uphold convictions for aggravated robbery.
  • Criminal law — Aggravated robbery — Eyewitness identification and corroboration — Evidence of purchasers and police recovering goods — Admissibility and weight of partially exhibited physical evidence — Appeal against conviction.
20 February 1991
The appellant's acts caused death; intervening medical treatment did not break the causal chain.
  • Murder — Causation — Section 207 Penal Code — Chain of causation — Effect of intervening medical treatment on criminal liability
19 February 1991
Application for leave to appeal refused where accounting records and credibility findings supported convictions.
  • Criminal law — theft by public servant and fraudulent accounting — sufficiency of evidence for monetary totals — trial magistrate's credibility findings — appellate interference with factual findings; leave to appeal refused.
19 February 1991
Death from complications clearly traceable to an assailant's conduct satisfies causation for murder despite later medical treatment.
  • Criminal law — Murder — causation where death occurs later from complications of injuries — intervening medical treatment — R v Jordan and Raymond Mweetwa Banda distinguished — original wound as an operating and substantial cause of death
19 February 1991
The court increased damages for the applicant’s false imprisonment and malicious prosecution to K2,000 plus interest and costs.
  • Criminal procedure and civil remedies — false imprisonment; malicious prosecution — assessment of damages — appellate review of trial judge's credibility and quantum findings — misuse of police arrest powers.
18 February 1991
Whether a novation created direct privity between the applicant and the respondent and whether supplied goods were properly rejected.
  • Contract law — Novation and privity — Agent’s ostensible authority to bind principal; waiver of time condition by conduct; rejection of goods — burden of proof and requirement to show nonconformity materially affected bulk; sub-contracting; costs following striking out.
18 February 1991
Supreme Court lacks jurisdiction to hear interlocutory appeals during pending criminal trials; challenges must await final appeal.
  • Criminal procedure — interlocutory appeals — Section 12 Supreme Court of Zambia Act — statutory construction against absurd results — Section 20 reservation — Article 20 fair hearing — s277 Criminal Procedure Code — procedural versus substantive jurisdiction
18 February 1991
Constructive trust imposed: appellant entitled to equal beneficial interest despite legal title in respondent's name.
  • Equity — constructive trust — partnership contributions and rescue of property — beneficial interest in land despite legal title — orders for sale or buyout; accounts.
18 February 1991
Bank not liable for loss caused by fraudulent withdrawals where customer’s authorised agent misled the bank; loss falls on customer.
  • Banker and customer — reliance on an authorised agent’s authority — fraud by customer’s employee — loss caused by agent’s ostensible/actual authority — banker not negligent to credit cheque in long-standing relationship
17 February 1991
Innkeeper strictly liable for theft of guest's car; car-park notice did not exempt hotel; replacement damages awarded.
  • Innkeeper liability — strict liability to guests for loss of property — car park within hospitium — notice in car park does not relieve liability on these facts — Occupiers Liability Act not applicable — Hotels Act then in force did not permit exclusion — damages assessed at replacement value.
14 February 1991
Reinstatement is available in the High Court but discretionary; damages are limited to contractual or customary notice and terminal benefits.
  • Employment law — Wrongful dismissal — Reinstatement available in High Court but discretionary; measure of damages by contract or customary notice; rejected early-retirement offer not a concluded agreement; terminal benefits include pension contributions refund.
14 February 1991
Identification shortcomings were cured by recovered stolen property and airgun, so convictions for robbery were upheld.
  • Criminal law — Robbery with violence — Identification evidence — Corroboration by recovery of stolen property — Admissibility of statements after inadequate warn and caution — Appeal against conviction dismissed.
6 February 1991
Identification defects were cured by recovered property and third-party confirmation; appeals against conviction dismissed; juvenile sentencing adjourned.
  • Criminal law — aggravated robbery; identification evidence and identification parades; inadmissibility of statements after inadequate warn and caution; recovered stolen property and third-party confirmation as corroboration; juvenile sentencing — welfare report required; mandatory sentence non-appealable.
6 February 1991
First appellant’s conviction quashed for insufficient evidence; second appellant’s conviction reduced to aggravated robbery and sentenced to 15 years.
  • Criminal law — amendment of charge during trial — necessity of fresh plea and opportunity to recall witnesses; Evidence — admissibility and sufficiency of post‑arrest admissions; Identification evidence — reliability where witnesses knew accused; Sentencing — substitution of conviction and sentence where material amendment ineffective.
5 February 1991
January 1991
A default judgment entered without hearing a defendant’s vital witness should be set aside for rehearing.
  • Civil procedure — Default judgment — Order 35 Rule 3 and Rule 5 — Setting aside judgment for good cause where defence prevented from being heard — Adjournment and counsel absence — Pleaded defence of forgery.
31 January 1991
Appellant’s murder conviction reduced to manslaughter; provocation and self-defence not established.
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29 January 1991
A court may not thwart the DPP’s constitutional power to enter a nolle prosequi; the resulting acquittal was quashed and nolle recorded.
  • Criminal law — Nolle prosequi — Constitutional power of DPP to discontinue prosecutions — Limits on judicial interference; Criminal procedure — Adjournment discretion — Proper exercise and inquiry; Effect of judicial refusal to accept nolle — Acquittal nullity.
22 January 1991
Appellant's appeals against manslaughter conviction and four-year sentence dismissed; eyewitness credibility and causation upheld.
  • Criminal law — Manslaughter — Assault causing death by septic infection — Credibility and bias of prosecution witness — Accused's right to silence — Sentence proportionality for violent conduct.
9 January 1991
Trial judge erred in acquitting without evidence where doubts arose from plea facts; acquittal quashed and retrial directed.
  • Criminal procedure — plea of guilty — where plea facts generate doubt record plea of not guilty and proceed to trial; cause of death — medical evidence not exclusive; improper acquittal; retrial ordered.
8 January 1991