Supreme Court of Zambia - 1992

39 judgments
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Results. 39 judgments found.

39 judgments
December 1992
A judge may not dismiss claims without hearing counsel where only part of the pleadings may be barred by Article 29(8).
  • Civil procedure — Amendment/striking out of pleadings — Court’s power to amend on its own motion exercised rarely and only in clearest cases — Article 29(8) constitutional bar to claims arising from Presidential detention — Dismissal for no cause of action without hearing counsel irregular — Proper procedure for challenging interlocutory orders
31 December 1992
A judgment creditor in possession under a writ of elegit must use best endeavours to realise property income and may be liable for wilful default.
  • Civil procedure — writ of elegit — Order 43 account against judgment creditor in possession — duty to realise income — liability for wilful default — disputed facts require oral evidence — writ of elegit excludes movables
31 December 1992
Custodial sentence upheld where large-scale, concealed cross-border drug trafficking justified enhanced penalties.
  • Criminal law — Sentencing — Unlawful possession of dangerous drugs — Large quantities, concealment and cross-border importation as indicia of trafficking — Application of Section 19A (enhanced penalties) — When aggravating circumstances justify custodial sentence for first offender
31 December 1992
Employer's promise to pay repatriation fares requires travel within a reasonable time (here 90 days); delay limits liability.
  • Employment law — Employer's obligation to provide repatriation passage — "Whenever ready to travel" constrained by reasonable time — Delay attributable to employee disentitles claimant to increased later fares — Estoppel limited
31 December 1992
Employer held vicariously liable for employee’s negligent driving; damages apportioned between statutory heads and awarded jointly and severally.
  • Negligence — motor-vehicle collision — vicarious liability of employer for servant’s negligent driving when passenger authorised; admissibility of police admissions; proper apportionment of damages between Law Reform (Miscellaneous Provisions) Act and Fatal Accidents Act; joint and several liability
31 December 1992
Restoration denied where systematic dishonesty and public/professional interest outweigh demonstrated rehabilitation.
  • Legal practitioners — Restoration to Roll — Disbarred for systematic theft — Section 33 discretionary and exceptional — public interest and professional reputation outweigh personal rehabilitation — conditional restoration considered but declined
31 December 1992
A driver who knows or should know of defective tyres is at fault for an accident caused by skidding.
  • Criminal law — Causing death by dangerous driving — Skid defence — defective tyres — onus on prosecution to prove skid due to driver’s fault — duty to inspect and exercise caution if vehicle known to be defective
31 December 1992
Failure to follow disciplinary rules and breach of natural justice justified reinstatement; damages limited due to mitigation duty.
  • Employment law — Wrongful dismissal — Failure to follow disciplinary code and grievance procedure; natural justice breached by interested adjudicators; unsubstantiated charges; reinstatement justified; mitigation of damages and assessment of back pay
31 December 1992
Res ipsa loquitur applied to a detached load on the road; defendant failed to rebut presumption of negligence.
  • Negligence — Motor collision caused by detached load — Application of res ipsa loquitur where dangerous thing under defendant's control — Distinction between Act of God and inevitable accident — Burden of proof on defendant to rebut presumption — Pleadings defects not fatal where evidence admitted and unchallenged — Upheld damages for loss of business
31 December 1992
Repair payment and signed release did not bar plaintiff's loss-of-use claim for lack of consideration.
  • Insurance/subrogation — Release form — Accord and satisfaction — Consideration — Part-payment rule — Unliquidated loss-of-use claim — "Without prejudice" marking — Estoppel/inequity
31 December 1992
A driver who knows or should know of defective tyres must inspect or drive cautiously; failure is dangerous driving.
  • Road traffic — Dangerous driving — Skid caused by defective tyres — Trial judge's misdirection on factual findings — Onus on prosecution where skid claimed — Driver's duty to inspect or exercise special caution if tyres are or may be defective
16 December 1992
Payment of undisputed repair costs without consideration does not bar a subsequent unliquidated loss-of-use claim.
  • Contract — Release/Accord and satisfaction — Part payment of undisputed repair costs does not constitute consideration for settling unliquidated loss-of-use claim; equity/estoppel — enforcement of gratuitous release unconscionable where claimant reserved other claims and received assurances; "without prejudice" generally inadmissible but unnecessary to decide here
7 December 1992
November 1992
An applicant alleging wrongful dismissal must plead and prove actual dismissal or a contractual breach, not mere redeployment.
  • Employment law — wrongful dismissal — constructive dismissal — redeployment versus dismissal — requirement to plead and prove breach of essential contractual term — no case to answer where claimant fails to establish primary facts.
25 November 1992
Appeal dismissed: daylight identification and corroborative circumstances upheld conviction and 15‑year sentence.
  • Criminal law — Aggravated robbery — Identification evidence — Opportunity to observe in daylight and subsequent recognition by victims — Minor discrepancies in clothing descriptions not fatal to identification; corroboration by apprehension and police visit to scene.
3 November 1992
October 1992
Restoration to the Roll demands special, compelling grounds; public interest and profession's reputation prevail over individual rehabilitation.
  • Legal practitioners — Restoration to Roll — Chief Justice's discretion under s.33 — requires special and compelling grounds — public interest and profession's reputation override individual rehabilitation — conditional restoration possible only with factual basis
25 October 1992
September 1992
29 September 1992
Robust criticism of a public figure in context was protected as fair comment; appeal dismissed with costs.
  • Defamation — fair comment — public interest — contextual reading of words — inferences from published article — absence of malice — elected public figure.
24 September 1992
An employer's obligation to provide repatriation passage is limited to a reasonable period (three months) after termination.
  • Employment law — expatriate repatriation passage — obligation to provide air tickets limited to a reasonable period (three months) post-termination — employee delay does not extinguish right but limits liability to ticket value within 90 days — employer not liable for fare increases due to employee's inordinate delay — limited estoppel
18 September 1992
9 September 1992
Court should not order or dismiss pleadings on its own motion without hearing counsel; interlocutory disputes require review or trial.
  • Civil procedure — Pleadings — Court-initiated amendment rare and should follow Order 8; striking out/dismissal only in clearest cases; presidential detention claims may survive if detention improperly enforced; improper conduct in refusing to obey interlocutory order; proper remedy is motion to review
8 September 1992
A judgment creditor in possession under a writ of elegit must use best endeavours and is liable for wilful default.
  • Civil procedure — Writ of elegit — Account under Order 43 — Judgment creditor’s duty to realise income — Liability for wilful default — Oral evidence required — Elegit does not extend to movables
8 September 1992
Wrongful dismissal found; exceptional circumstances justified reinstatement, but damages limited by duty to mitigate to 12 months' salary.
  • Employment law — Wrongful dismissal — Failure to follow disciplinary code and natural justice — Interested members on disciplinary committee — Exceptional circumstances warranting reinstatement — Duty to mitigate damages; damages limited to 12 months' salary plus arrears
3 September 1992
August 1992
A driver who knows or ought to know of dangerously defective tyres is at fault if a resulting skid causes death.
  • Causing death by dangerous driving — skid due to defective tyres — driver’s duty to inspect and report defects or drive cautiously — once skid accepted prosecution must prove driver’s fault — trial misdirection on facts
28 August 1992
Res ipsa loquitur applied; defendant failed to rebut negligence for an unsecured tank causing the collision.
  • Negligence — road obstruction by detached trailer load; res ipsa loquitur shifts burden to defendant; Act of God/inevitable accident defence; burden of proof for latent defect; pleadings vs. unobjected evidence on negligence and loss of business
28 August 1992
Aggravating factors, including trafficking and transient status, justified denying the appellant the option of a fine and imposing custody.
  • Sentence — custodial term without option of fine justified where aggravating circumstances (trafficking, importation, concealment) exist; Dangerous Drugs Act s.19A engaged; aggravating facts need not be pleaded in particulars; fines may be ineffective for transient offenders
24 August 1992
July 1992
28 July 1992
The applicant's defences of act of God, inevitable accident, latent defect and res ipsa loquitur failed; appeal dismissed with costs.
  • Tort — negligence — defences: act of God, inevitable accident, latent defect, res ipsa loquitur — burden of proof shifts to defendant to rebut inference of negligence; pleadings — failure to object to unpleaded evidence may permit its consideration; damages — unchallenged evidence of business loss may suffice
15 July 1992
June 1992
Employer vicariously liable despite passenger prohibition; damages must be apportioned and criminal outcomes not generally determinative of civil negligence.
  • Vicarious liability — prohibition on carrying passengers does not negate employer liability; Damages — global awards improper, must apportion between Law Reform Act and Fatal Accidents Act and adjust for inflation; Civil negligence — criminal convictions generally inadmissible except for admissions; Quantum — increased award for loss of expectation of life
20 June 1992
March 1992
Payment of undisputed repair costs and a signed release did not bar the plaintiff's unliquidated claim for loss of use absent fresh consideration or inequity.
  • Tort — damages for loss of use — release and accord and satisfaction — part payment of undisputed repair costs insufficient consideration to discharge separate unliquidated claim — estoppel and inequity — "without prejudice" marking considered but not decisive
20 March 1992
Repatriation passage must be claimed within a reasonable period; employer not liable for fare increases caused by employee delay.
  • Employment law — repatriation passage on termination — entitlement must be exercised within a reasonable time — "whenever ready to travel" does not permit indefinite delay — employer not liable for fare increases due to employee's delay — measure of recovery is fare value within reasonable period
19 March 1992
Whether a D.P.P.'s public non-prosecution precludes later prosecution absent fresh evidence and trial judge's failure to address biased eyewitness credibility.
  • Evidence—affidavit evidence on contentious matters; Criminal procedure—coroner’s order vs D.P.P. discretion; Prosecution reopened after D.P.P. public non-prosecution—requirement of fresh evidence; Amendment of charge—power to upgrade information; Credibility—warning as to interested witnesses; Self-defence—objective and subjective tests
19 March 1992
Employer held vicariously liable for employee's negligent driving; damages allocated between statutory heads and adjusted for inflation.
  • Negligent driving — vicarious liability of employer for employee’s driving — authority to carry passengers and employer’s onus — admissibility of driver’s police admissions in civil negligence — allocation of damages between Law Reform (Miscellaneous Provisions) Act and Fatal Accidents Act — quantum adjusted for inflation
19 March 1992
Restoration to the Roll denied where systematic dishonesty undermined public interest despite subsequent rehabilitation.
  • Legal practitioners — restoration to the Roll under section 33 — disbarment for misappropriation/theft — public interest and profession’s reputation paramount — repentance and rehabilitation relevant but not overriding — restoration a rare remedy
19 March 1992
D.P.P.'s public non‑prosecution bars later prosecution absent fresh evidence; trial judge misdirected on witness bias and self‑defence succeeds.
  • Affidavit evidence on contentious matters; Rule 39(1)
  • Supreme Court Rules — Bail on appeal in murder cases — Rule 45(2) and s.123 C.P.C. — Coroner's order naming persons to be charged — D.P.P.'s public non‑prosecution and reopening of prosecution — Amendment of information under s.273(2) C.P.C. — Witness bias and credibility — Self‑defence: honest and reasonable belief in imminent danger
18 March 1992
A landlord is bound by reasons in a notice to quit; s11(1)(e) requires proof of superior tenancy and intent to dispose as whole for better yield.
  • Landlord and tenant — notice to quit binds landlord to reasons stated — Section 11(1)(e) Cap.440 requires proof of superior tenancy and intention to let/otherwise dispose of whole property for better rental yield — Section 11(2) five-year bar protects recent purchasers/transferees — transferee cannot evade protection by administrative transfer — essential evidentiary requirements to oppose grant of new tenancy.
15 March 1992
A dismissal for want of cause was irregular where strike‑out should be reserved for clearest cases and counsel must be heard before dismissal.
  • Civil procedure — Amendment and striking out of pleadings — Article 29(8) and claims arising from presidential detention — Strike‑out reserved for clearest cases — Irregular dismissal without hearing counsel — Improper correspondence by counsel refusing judicial order
3 March 1992
Six-year custodial sentence for trafficking-related possession upheld; aggravating factors justified imprisonment despite first-offender plea.
  • Sentencing — possession of large quantity of dangerous drugs — trafficking inferred from quantity and concealment — first-offender principle v. aggravating circumstances — Section 19A Dangerous Drugs Act — enforcement of fines against transient/foreign offenders — trans-border drug trafficking deterrence
3 March 1992
Court found wrongful dismissal due to procedural unfairness and unproven charges, ordered reinstatement and limited damages.
  • Employment law — wrongful dismissal — failure to follow disciplinary code and grievance procedure — breach of natural justice by interested disciplinary committee members — exceptional circumstances justifying reinstatement — mitigation of loss and measure of damages
3 March 1992
February 1992
Possession of distinctive stolen goods and implausible explanation upheld conviction for aggravated robbery; statutory minimum sentence affirmed.
  • Criminal law — Aggravated robbery — Circumstantial evidence and possession of distinctive stolen goods — Credibility findings — Defence of lawful possession for safekeeping — Police investigation of alleged third party — Statutory minimum sentence non-appealable.
5 February 1992