Supreme Court of Zambia - 1998

40 judgments

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40 judgments
Citation
Judgment date
December 1998
An unregistered collective agreement has no legal force; Ministerial approval is required before enforcement.
Labour law – Industrial and Labour Relations Act – Registration and legal effect of collective agreements – Ministerial approval required – Labour Commissioner's role – Wage freeze and enforceability.
31 December 1998
Whether payrolls or bank changes varied written salary terms and whether a negotiated final settlement barred further allowance claims.
Employment contract interpretation – salary clause specifying 70% through Bank of Zambia – payment method and currency; variation by payroll; final settlement extinguishing post-contract claims; statutory provident fund claims against employer.
29 December 1998
2 December 1998
November 1998
A written offer with essential terms and deposit formed a binding sale; time was not of the essence and specific performance was granted; intervening purchaser had constructive notice.
Contract Law – Statute of Frauds: writing or memorandum sufficient if it contains material terms; Time – when time is of the essence; Specific performance – preferred remedy for land; Bona fide purchaser – constructive notice from tenant's possession defeats purchaser without notice.
30 November 1998
Court upheld order for re‑valuation and accounting of sold mortgaged properties and stayed execution pending accounting.
Mortgagee’s duty to obtain best possible price – re‑valuation of sold mortgaged properties at date of sale permissible – retrospective valuation allowed (deduct improvements) – account of sale and stay of execution where mortgagee failed to account.
25 November 1998
Section 30(1) requires elections but permits directory/procedural flexibility; administration-proposed procedure accepted by staff does not void election.
University Act s.30(1) – Election of Deans/Directors – requirement to hold elections mandatory but procedural form directory; Mandatory versus directory statutory provisions; Declaratory relief discretionary; Validity of election where staff acquiesce to administrative procedure.
24 November 1998
A court should not bar the applicant from representing an accused merely because the applicant may be called as a witness; withdrawal is desirable, not mandatory.
Criminal procedure – advocate as witness – statements at the bar are not evidence – presence in court does not automatically disqualify a witness – desirability (not illegality) of withdrawal where counsel may be called as witness – Order 5 High Court Rules applies to civil, not criminal, proceedings.
17 November 1998
Whether the respondent met constitutional citizenship/parentage qualifications and whether electoral flaws vitiated the presidential election.
Constitutional law – Presidential election – candidate qualifications (citizenship and parents) – acquisition of citizenship at independence; Article 41(2) – "full bench" defined; Legal ethics – ministers as counsel; Standard of proof – high in national election petitions; Electoral law – treating, bribery allegations, irregularities and systemic flaws (duplicate NRCs, register errors) – insufficiency to vitiate nationwide result.
9 November 1998
Resignation not set aside where forged board minute justified potential summary dismissal; no pleaded claim for emoluments or shares.
Employment law – resignation alleged to be induced by duress – forged/cooked board minute – misconduct justifying summary dismissal – burden of proof on employee to establish coercion – no pleaded claim for withheld emoluments or shares.
5 November 1998
Conviction upheld where possession of recently stolen property corroborated identification despite potentially interested witness.
Criminal law – Aggravated robbery – Identification evidence – Witness with possible interest/accomplice – Corroboration by possession of recently stolen property – Mandatory minimum sentence.
5 November 1998
Provocation insufficient to reduce murder but may mitigate sentence; multiple aggravated robberies with severe injury justify harsher than minimum sentence.
Refusal of provocation defence where violence is disproportionate; extenuating circumstances under Section 202(a)&(b) mitigate sentence; sentencing: back-dating custody, mandatory minimums, multiple offences and severe injury justify increased sentence
3 November 1998
Trust for purchaser who paid purchase money but had title registered in another’s name held lawful under s.4(i); transfer ordered.
Trusts Restriction Act — s.3(c) prohibition on dispositions vesting property in possession at a future date — s.4(i) exception for trusts terminable at beneficiary's will — resulting/constructive trust where purchaser funds purchase but title taken in another's name — equity will not permit illegality to be used as instrument of fraud.
2 November 1998
October 1998
Whether the court should vary its judgment to deem the applicants retrenched from the judgment date rather than redundancy date.
Civil procedure – Variation of judgment – Rule 78 – correction of alleged slip or omission – whether effective date of retrenchment may be altered; Employment law – unlawful redundancy – legal effect of null and void redundancy and entitlement to damages; Unjust enrichment considered in varying judgments.
30 October 1998
A late, five‑year challenge to the Court's judgment on alleged non‑party status was frivolous and dismissed with costs.
Appeal – parties – joinder by leave to appeal – validity of appeal where appellant was not party in lower court; Review of court's own judgment – rarity and rule 78; Abuse of process – late challenge to final judgment; Costs against counsel for frivolous motion.
30 October 1998
Applicant summarily dismissed unlawfully; six months’ pay upheld and damages for distress increased to K2,000,000.
Employment law – wrongful/summary dismissal – fixed-term contract without termination clause – reasonable notice in lieu (six months) – duty to mitigate – damages for mental distress increased for inflation and precedent – interest discretionary.
30 October 1998
Defamation award reduced due to limited publication, lack of evidential production, and inadequate factual findings.
Defamation — assessment of damages — broadcast in vernacular, single late‑night transmission, anonymous letter not produced — failure to make specific factual findings — appellate reduction of excessive award.
30 October 1998
A director’s formation of a competing company can justify an interim injunction to protect the applicant’s operations pending trial.
Company law – interim injunction – director/shareholder forming competing company – conflict of interest – alleged interference with corporate contracts – relevance of section 216 Companies Act questioned but not decisive.
27 October 1998
Appellate court refuses to overturn conviction where trial judge's credibility findings were reasonable and well‑reasoned.
Criminal law – aggravated robbery – credibility findings – appellate review standards (NKHATA; RISBEY) – when appellate court may interfere with trial judge’s factual findings – fabricated defence story – demeanour evidence.
6 October 1998
September 1998
Appeal over awards for a child's wrongful death: life-expectancy award reduced for unreasonableness; funeral costs upheld.
Damages — assessment of loss of expectation of life for a child — quantum and reasonableness — judicial notice of inflation — special damages for funeral expenses assessed without receipts where evidence not controverted.
10 September 1998
The plaintiff entitled to refund and damages for breach; conversion damages cannot be added; foreign-currency reconversion disallowed.
Sale of Goods Act – seller's failure to deliver – measure of damages for breach (difference between contract price and market price at time goods should have been delivered); Conversion – normal measure market value at time of conversion; damages for breach cannot be combined with conversion damages for same goods; Kwacha-denominated awards must not be hedged by reconverting via past foreign-currency rates; long delay and interest (100% p.a. simple) considerations.
3 September 1998
August 1998
Appellate intervention requires a 'sense of shock'; guilty plea upheld; trafficking sentence reduced to two years concurrent.
Criminal law – Plea of guilty – Pleas entered with legal representation – Validity and withdrawal; Trafficking in drugs – Statutory quantity as aggravation; Sentencing – Appellate interference only where sentence evokes 'sense of shock' or is wrong in principle; Concurrent sentences; Elements of offence and obligation to explain charges.
25 August 1998
Court upheld aggravated robbery convictions based on credible eyewitness identification and apology, affirming the mandatory 15-year sentence.
Criminal law – Aggravated robbery – Identification evidence and credibility – No identification parade – Apology/confession at police station as corroboration – Mandatory minimum sentence upheld.
11 August 1998
Directors may sue in the company's name against a receiver who is the wrongdoer or neglects to act.
Company law — Receivership — Receiver's fiduciary duty and liability — Locus standi of company under receivership — Exceptions permitting directors/shareholders to sue in company's name when receiver is wrongdoer or neglects to act.
3 August 1998
Whether retrenchees’ termination payments in lieu of notice must be computed using salary increases effective during the notice period.
Employment law – retrenchment/early retirement – payment in lieu of notice – whether payment effects immediate termination – effect of subsequent salary increase during notice period – contractual interpretation (accommodation clause).
3 August 1998
July 1998
Importation under section 7 is not a cognisable offence and is bailable; Supreme Court cannot grant bail absent an appeal from conviction.
Criminal law – Bail – Narcotic Drugs and Psychotropic Substances Act – Distinction between importation (s.7) and trafficking (s.6) – Whether importation is cognisable and non-bailable – Appellate court’s lack of power to grant bail absent appeal from conviction.
27 July 1998
June 1998
An appellant's failure to comply with an 'unless' order and unexplained delay precludes setting aside automatic dismissal.
Civil procedure – Appeal – Failure to lodge record of appeal within time – 'Unless' order – Automatic dismissal – Relief only in very exceptional circumstances – Inordinate delay – Strict compliance with procedural time limits.
2 June 1998
Whether consolidated salary increases were valid where management paid converted perquisites to employees as instructed.
Company law – authority and holding out – Companies Act ss.23–25 – employer bound by acts of representative; Employment law – salary consolidation and conversion of in-kind perquisites into allowances; Evidence – payslips and auditors’ records establishing payment; Claim for withheld differences – merits.
2 June 1998
The court increased the applicant’s sentence for multiple aggravated robberies involving severe injury and backdated it to arrest.
Criminal law – Aggravated robbery – Sentencing – Credit for time in custody and back-dating sentences – Multiple offences and serious bodily injury (axing) as aggravating factors – Appropriateness of imposing statutory minimum sentence.
2 June 1998
Court increased sentence for multiple aggravated robberies with severe injury and back-dated it to the arrest date.
Criminal law — Aggravated robbery — Mandatory minimum sentence — Multiple offences and serious injury as aggravating factors — Back-dating sentence to date of arrest.
2 June 1998
April 1998
Committal for breaching an injunction requires a written notice endorsed with the penal notice; mere knowledge is insufficient.
Civil procedure – Contempt/committal for breaching an injunction – Requirement of penal notice under Order 45 Rule 7(4) – Note to Rule 7(7) applies only where insufficient time to prepare written notice – Mere knowledge of injunction insufficient if written notice lacks penal endorsement.
29 April 1998
Whether money held in an advocate's client account earns interest and whether an advocate is liable when the bank collapses.
Banking law – clients' account – whether money in a client's account earns interest; money had and received – remedy for recovery of client funds; advocates' liability where bank holding client funds is liquidated; costs and interest awards.
14 April 1998
March 1998
The appellant bank was held liable for failing to insure the respondent's imported machinery in transit; appeal dismissed.
Contract/loan security – Interpretation of insurance clause – Duty to insure goods in transit – Effect of retained insurance funds (US$2,500) – C.&F. vs C.I.F. invoice not determinative – Damages for loss of business.
19 March 1998
Circumstantial evidence, including escape from custody, upheld the murder conviction and confirmed the death sentence.
Criminal law – Murder – Circumstantial evidence – Escape from custody as relevant inference – Proof beyond reasonable doubt – Credibility and preference of witnesses.
3 March 1998
3 March 1998
Share purchase indemnities between shareholders do not defeat a third‑party creditor's claim; company remains a distinct legal person.
Company law – separate legal personality of a company – corporate liabilities remain enforceable despite change of shareholders – share purchase agreement indemnities do not defeat third‑party creditors’ claims – joinder of unrelated third parties and amendment to raise shareholder indemnities refused.
2 March 1998
A Registrar lacks power under Order 39 to review his own decision; an assessment review was unjustified.
Civil procedure – review – Order 39 High Court Rules – whether a Registrar may review his own decision – assessment of damages – competence of post-assessment review.
2 March 1998
February 1998
Oral sale agreement enforced; valuation order reversed; mesne profits awarded from date of judgment; improper appellate documents expunged.
Contract law – oral contract for sale of land – specific performance; proprietary estoppel; remedy – valuation reversed in favour of contract terms; damages – mesne profits accrue from date owner's interest is extinguished (date of judgment); civil procedure – supplementary record expunged; cross-appeal amendments require leave.
13 February 1998
Court affirmed specific performance of a 1975 house sale, rejected foreign‑currency reconversion, and ordered interest and rates adjustments.
Specific performance – parallel proceedings and res judicata – measure of damages for defective title – monetary loss measured at time of breach – rejection of foreign‑currency reconversion of historic Kwacha value – award of interest and reimbursement of rates.
9 February 1998
January 1998
Employer’s dismissal upheld where employee was heard and no breach of natural justice; damages limited to notice period.
Employment law – disciplinary proceedings and wrongful dismissal – rules of natural justice – attendance of HR officer at appeal – fresh evidence and right to be heard – measure of damages for wrongful dismissal limited to contractual notice period (Kamayoyo).
30 January 1998
Weak dock identification and conflicting witness testimony made robbery and attempted murder convictions unsafe, leading to conviction for receiving stolen goods.
Criminal law - Identification evidence - dock identification without parade; Circumstantial evidence - possession and recovery of stolen property; Misdirection by trial judge; Proviso in criminal appeals; Receiving stolen property - conviction and sentence.
20 January 1998