Supreme Court of Zambia - 2002

122 judgments

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122 judgments
Citation
Judgment date
March 2002
Appeal allowed where trial court's finding of exoneration was perverse, report showed supervisory negligence.
Employment law — unfair dismissal — disciplinary dismissal for gross negligence — supervisory negligence in money order frauds — appellate intervention where trial court's factual finding is perverse or unsupported by evidence.
5 March 2002
Unexplained year-long delay justified refusal of out-of-time review; interest on claim runs from date of the writ.
Civil procedure – review out of time – inordinate delay – leave to apply for review; Interest – commencement date – interest on claim in foreign currency runs from date of writ to date of judgment (Shanzi; Bank of Zambia v Anderson).
5 March 2002
Whether summary dismissal justifies damages beyond contractual benefits to compensate distress and difficulty obtaining similar work.
Wrongful dismissal – Measure of damages – Contractual or reasonable notice as normal measure – Departure permitted for traumatic/summary dismissals – Award of non-pecuniary (Mpundu-type) damages – Excessive award of two years’ earnings reduced to six months.
5 March 2002
Employer terminated employee on extended study leave without hearing; dismissal harsh but damages not justified given employer's benefit.
Employment law – study leave and sponsorship – termination for failure to return from study leave – procedural fairness/natural justice – entitlement to recover training costs – damages for wrongful dismissal.
5 March 2002
February 2002
Court reduced an inflated loss-of-business award due to unreliable projections and confirmed ancillary replacement costs.
Assessment of damages; loss-of-business projections; reliability of amended affidavits; mitigation of loss; limiting period of damages; interest on awarded damages.
27 February 2002
Judgment on admission may be entered at Scheduling Conference, but proper service and opportunity to amend defence are required for procedural fairness.
Commercial procedure – Practice Direction 2 – Defence must specifically traverse each allegation; general denials insufficient – Scheduling Conference – court may enter judgment on admission at Scheduling Conference without separate motion – service of notice and procedural fairness required before entering judgment in absentia.
25 February 2002
The court upheld retirement for misconduct, finding the applicant's procedural complaints insufficient to overturn credibility-based findings.
Administrative law – judicial review of retirement in the public interest; procedural fairness – right to be heard and show-cause procedures; procurement law – tender procedures and alleged breach of Zambia National Tender Board Act s.19; appellate deference to trial judge’s credibility findings.
20 February 2002
An agreement to agree is not a binding lease, but equity allows reimbursement for improvements requested by the prospective tenant.
Contract law – agreement to agree versus concluded lease; State consent under Land (Conversion of Titles) Act; conditional contracts; equitable relief and quantum meruit for improvements; mesne profits/damages for loss of rent not recoverable where no binding lease.
20 February 2002
A judgment creditor who takes possession but willfully fails to realize income may be required to account and have an inquiry credit the debtor; defective elegit/charging orders and private sale were set aside.
Civil procedure – Enforcement of money judgment – Charging orders and elegit – Requirement to follow Order 50 RSC, Order 88 RSC and elegit practice (Order 42) – Mortgagee-like duties when in possession – Inquiry and credit where judgment creditor willfully fails to realize income – Irregular sale quashed.
19 February 2002
The instructing client remains primarily liable for lawyers' fees even if a third party later assumes conduct or benefits.
Professional services – recovery of legal fees – instructing client primarily liable – third party takeover does not extinguish instructing client's liability – counsel’s duty of candour – trial adjournment refusal.
19 February 2002
Insufficient proof of value requires reassessment of damages; costs deprivation of a successful party requires clear, blameworthy reasons.
Damages – pecuniary damages – proof of value – where evidence of value is inadequate, refer assessment to Deputy Registrar – discretion to deprive successful party of costs must be judicially exercised with explicable reasons.
19 February 2002
A plaintiff must prove the market value of lost goods; absent proof, courts should refer quantum for assessment rather than fix arbitrary damages.
Damages — Pecuniary loss — Necessity to prove market value at time of loss — In absence of specific evidence referral for assessment preferable to arbitrary global award; Costs — discretion to deprive successful party must be judicial and based on explicable blameworthy conduct.
19 February 2002
Where proof of loss is inadequate, damages should be assessed by the Deputy Registrar; costs deprivation requires blameworthy conduct.
Landlord and tenant – Business premises – unlawful lock-up and alleged conversion/damage of goods – proof of value – where evidence inadequate matter to be referred to Deputy Registrar for assessment – measure of damages for conversion – costs discretion requires blameworthy conduct.
19 February 2002
Appeals allowed: contractual termination by payment in lieu upheld; erroneous order permitting re-entry and distress set aside with costs.
Employment law – termination by payment in lieu of notice – contractual terms in appointment letter and employee manual govern; Civil procedure – discrepancy between oral ruling and formal order; re-entry and distress – invalid re-entry/execution under erroneous order; costs.
15 February 2002
A clearing agent who bonds transit exports is liable for duties and fines where purported exports are fraudulent; licence suspension was lawful.
Customs and Excise — Clearing agent bonds — Liability under s.183 for duties, VAT, interest and fines where removals in transit are fraudulent — Licence suspension pending payment lawful — Foreseeable business risk — Connivance by revenue employee no bar to agent's liability.
14 February 2002
A trade mark cannot be expunged without following statutory procedures; passing-off hinges on likelihood of deception to ordinary customers.
Trade marks — Expunction/rectification procedure — must follow Trade Marks Act (ss.37,38); registration prima facie evidence (s.57); s.9(4) limits infringement between registered proprietors; passing-off independent — test is likelihood of deception to the ordinary average customer.
8 February 2002
January 2002
Specific performance ordered where evidence conclusively established payment of the deposit despite the trial judge’s contrary finding.
Specific performance – contract for sale of land – payment of deposit – sufficiency of evidence and appellate interference with trial judge’s factual finding – possession and improvements by purchaser.
25 January 2002
Appeal dismissed: court upheld trial judge's resurvey/demarcation to give effect to ambiguous land bequests.
Wills — ambiguous bequests as to land extent — reliance on contemporaneous approved survey diagram — role of trial judge's site inspection and factual findings — appellate reluctance to disturb demarcation and resurvey orders.
17 January 2002
Judicial review cannot be used to challenge Acts of Parliament amending the Constitution; Parliament may alter the Constitution subject to Article 79 procedures.
Constitutional law – constitutional amendment – Article 79 – parliamentary power to alter Constitution; judicial review not available to challenge Acts of Parliament; basic-structure doctrine distinguished and not recognized in Zambian law; referendum requirement for Part III (fundamental rights).
12 January 2002
Judicial review is "process" under s.164; the Act’s mandatory three‑month limit bars late actions against customs officers.
Customs and Excise – meaning of "process" in s.164 – whether judicial review falls within s.164(1) – Commissioner‑General/Controller as "officer" – s.164(4) three‑month limitation mandatory, no judicial extension under Order 53.
11 January 2002
The Supreme Court lacks jurisdiction to stay execution of its own final judgment pending separate High Court proceedings.
Civil procedure — Stay of execution — Supreme Court has no jurisdiction to stay its own final judgment; statutory stay under rule 18 only applies while appeal pending.
4 January 2002
High Court lacks jurisdiction to arrest an ongoing presidential election; judicial review requires a concrete decision and cannot stay declaration.
Constitutional law – Presidential election – Jurisdiction of courts – Article 41 and Electoral Act – Judicial review – Requirement of reviewable decision – Returning Officer’s duties and lack of discretion to delay declaration.
1 January 2002