Supreme Court of Zambia - 2003 September

25 judgments

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25 judgments
Citation
Judgment date
September 2003
Consent order limited to that cause does not bar fresh claims for mesne profits or rent where defendant remained in occupation until court order.
Procedure — Consent order — Effect of consent order limited to the cause in which made; does not bar fresh action on matters not consented to. Landlord & tenant/Property — Mesne profits/occupation charges — entitlement where defendant remains in possession until court-ordered vacation despite lack of new lease. Civil procedure — Order 113 not a bar to subsequent remedies not agreed in consent order
26 September 2003
Consent order for possession did not bar subsequent claim for mesne profits; plaintiffs entitled to occupation charges for period of continued occupation.
Civil procedure – consent order – scope and effect of consent orders; property law – mesne profits/occupation charges – recoverability where occupant remains after change of ownership; tenancy – absence of fresh lease does not bar claim for occupation charges where possession retained without payment to new owner.
26 September 2003
Appellant’s election annulled for committing an illegal practice by publishing false statements that the rival party had dissolved.
Election law – illegal practice – Regulation 56(1) (publication of false statement of withdrawal/party dissolution) – attribution to candidate/agents – procedural fairness in election petitions – Article 72(2) limit to appeals (questions of law only).
24 September 2003
Proof of a single corrupt or illegal act by the applicant can void the election.
Election law – Election petition – Standard of proof higher than balance of probabilities but less than beyond reasonable doubt; proof of any one corrupt or illegal practice suffices to void an election; misuse of public resources (drug kits, Constituency Development Fund), government transport and facilities as electoral misconduct.
23 September 2003
Whether breaches of electoral law and an agent’s alleged intimidation nullified the respondent’s election under section 18.
Electoral law – section 18(2)(b) & (4) – non‑compliance and ‘substantial conformity’ doctrine – effect on election result; Electoral law – section 18(2)(c) – corrupt/illegal practices and agent intimidation; Standard of proof in election petitions – higher standard; Appellate jurisdiction – Article 72 limits review of factual findings.
23 September 2003
Misuse of state resources and irregular procurement aimed at influencing voters nullified the election under section 18(2)(a) of the Electoral Act.
Electoral law – Election petition – Standard of proof higher than balance of probabilities but less than beyond reasonable doubt – Misuse of public property, transport, drugs and constituency funds – Section 18(2)(a) Electoral Act – Government facilities cannot be authorised for campaigning.
23 September 2003
A company in liquidation cannot be subjected to execution before liquidation concludes; writs against the liquidator are improper.
Liquidation — Execution stayed until completion of liquidation; writs of fifa against a liquidator improper; creditor ranking and priority; unlawful seizure of non-company property.
23 September 2003
Compound interest requires express agreement or clear acquiescence; bank penalties for late payment are prohibited.
Banker and customer – Compound interest requires express agreement or clear acquiescence/custom; vague "bank practice" clause insufficient; Banking and Financial Services (Cost of Borrowing) Regulations prohibit penalties or charges for late repayments; courts to award realistic interest guided by prevailing commercial practice.
18 September 2003
17 September 2003
17 September 2003
Application to correct judgment under Rule 78 denied; retrial order was intentional, not an accidental slip.
Civil procedure — Correction of judgments — Rule 78 and inherent jurisdiction — Scope limited to accidental slips expressing manifest intention — Cannot vary judgment for errors of law or mere dissatisfaction — Power to order new trial (s.25 Supreme Court Act) — Distinction from rescission where procedural unfairness or bias established.
16 September 2003
The applicant's slip-rule bid to replace an ordered retrial with dismissal was refused for lack of any accidental error.
Civil procedure – Rule 78 (slip rule) – correction of accidental errors or omissions in judgment – inherent jurisdiction to vary orders – limits on varying a deliberate appellate decision – severance of issues and ordering of retrial.
15 September 2003
Appellant awarded assessed exchange-loss converted to pounds with LIBOR interest where contract was not a Kwacha transaction.
Contract and currency – assessment of exchange-loss arising from devaluation – consent order directing Deputy Registrar – transaction held not to be Kwacha transaction – acceptance of uncontradicted expert quantification – conversion to Pounds and LIBOR interest ordered.
9 September 2003
Appeal dismissed: Board‑approved negotiated redundancy package valid; unauthorized allowance increases not payable; interest discretionary.
Employment law – redundancy/retrenchment – validity and effect of Board‑approved packages – statutory requirement for Board approval of salary/allowance variations – discretion to award interest – pleadings and scope of appeal – repayment of pension contributions and repatriation allowances.
9 September 2003
Where liability is found but special damages are unproven, assessment may be remitted to the Deputy Registrar.
Civil procedure — Order 39 review applications — requirement to show evidence is fresh (ZCCM v Moffat Sinkala) — proof of special damages — referral to Deputy Registrar for assessment where liability established but special damages unproven.
9 September 2003
Resignation to avoid disciplinary dismissal is not constructive dismissal; statute limits pensionary recovery to refund of member contributions.
Employment law – resignation to avoid disciplinary dismissal does not constitute constructive dismissal; LASF Act s32 limits benefits for resignation to avoid dismissal to refund of member's contributions; entitlement to retirement/pension depends on pensionable age and statutory amendments; withholding terminal benefits and counter-claim procedural requirements.
6 September 2003
Appeals dismissed: insufficient evidence for extra allowances and judgment satisfied by execution; separate action was abuse of process.
Civil procedure — assessment of damages; execution as satisfaction of judgment; entitlement to allowances — requirement of evidence; abuse of process — multiplicity of actions on same subject; incorporation of perquisites into salary depends on contractual/administrative directives.
5 September 2003
3 September 2003
The appellant's challenge to aggravated robbery conviction and mandatory 15-year sentence was dismissed after he was found to be an adult.
Criminal law – aggravated robbery – identification by victim and possession of stolen property – conviction upheld; Mandatory minimum sentence – 15 years – no appeal lies; Juvenile status – medical and social welfare evidence determinative.
3 September 2003
Whether the IRC may rely on untested affidavit evidence and whether the appellant rebutted gross negligence and proved wrongful or discriminatory dismissal.
Industrial relations – admissibility of affidavit evidence – Rule 64 IRC – Court of substantial justice and section 85(5) – weighing untested affidavit and viva voce evidence; Employment law – standard of proof in civil dismissal disputes – balance of probabilities; Employment law – gross negligence of duty – burden to rebut and appellate review of factual findings; Employment law – constructive dismissal vs. actual dismissal; Remedies – salary arrears, pension contributions, redundancy-equivalent claims – factual onus.
2 September 2003
Appeal dismissed: IRC’s factual finding of lawful dismissal for false accounting was supported by evidence, falling outside this Court’s jurisdiction.
Labour law – dismissal for false accounting – findings of fact by Industrial Relations Court – appellate jurisdiction under section 97 ILR Act – factual findings reviewable only if unsupported or perverse – procedural fairness (ZIMCO conditions) not determinative where substantive misconduct proved.
2 September 2003
2 September 2003
A party defending a petition discontinued by the other is entitled to costs and a subsequent similar petition may be stayed until those costs are paid.
Election law – costs on discontinuance of petition; High Court Rules Order XVII r.2 – stay of subsequent suit until costs paid; duplicative election petitions; civil procedure – costs and stay.
2 September 2003
Action dismissed for want of prosecution after inordinate delay caused prejudice; issues of illegality and accord and satisfaction reserved for trial.
Civil procedure — Restoration to active cause list — Dismissal for want of prosecution — Inordinate and inexcusable delay causing prejudice — Substitution of parties where defendants died — Illegality and accord and satisfaction are triable issues.
2 September 2003
Post‑termination circulars cannot confer benefits on a dismissed employee; employer must refund retained security; gratuity is tax‑free.
Employment law – wrongful dismissal declared a nullity; refund of employer-retained security even if not pleaded; post-termination changes to conditions of service do not confer benefits; redundancy/surplus-labour circular inapplicable to dismissed employee; long service gratuity tax-free under conditions of service.
2 September 2003