Supreme Court of Zambia - 2010

20 judgments

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20 judgments
Citation
Judgment date
December 2010
Appeal dismissed: armed robbery conviction and sentence upheld where accused refused counsel, failed to plead, and were in recent possession of stolen property.
Criminal law – Armed robbery – Particulars versus statement of offence – conviction under Section 294(2) valid where particulars allege firearms and charge explained; Right to counsel – choice – refusal to instruct counsel and absconding forfeits claim; Plea (s.204) – absence created by accused cannot vitiate trial; Evidence – recent possession and circumstantial coincidences sustain conviction.
9 December 2010
November 2010
Substituting a closely related offence did not breach natural justice; evidence supported lawful dismissal of the applicant.
Employment law – unfair dismissal – substitution of charges – natural justice – misappropriation of funds v gross negligence – similar ingredients – disciplinary fairness – employer entitled to dismiss dishonest employee.
12 November 2010
Murder conviction upheld; death sentence set aside and reduced to 15 years’ imprisonment due to belief in witchcraft as an extenuating factor.
Criminal law – Murder – Eyewitness credibility; Confession evidence – oral confession and failure to produce written statement; Dereliction of duty – failure to produce document; Sentencing – belief in witchcraft as extenuating circumstance reducing death sentence to fixed term imprisonment.
2 November 2010
Overwhelming circumstantial evidence and recent possession can sustain murder and aggravated robbery convictions even if a contested confession is excluded.
Criminal law — Murder and aggravated robbery — Circumstantial evidence — Doctrine of recent possession — Confession/admissibility — Language dispute as general issue (no trial-within-a-trial required) — Conviction sustainable even without disputed confession.
2 November 2010
October 2010
A mareva injunction requires solid evidence of real risk of asset dissipation; speculative fears warrant setting it aside.
Mareva injunction – pre-judgment freezing orders – requires solid evidence of real risk of asset dissipation; ordinary interlocutory injunction principles (adequacy of damages) subordinate; injunctions must be clear, limited to value of claim, and accompanied by undertakings and penal notice.
19 October 2010
Court censured counsel for facilitating a frivolous appeal, varied costs order, and apportioned taxed costs between counsel and appellant.
Civil procedure — wasted costs — counsel’s duty to court and client — withdrawal of representation — professional misconduct — apportionment of taxed costs — defective service and omission of show‑cause period.
12 October 2010
12 October 2010
September 2010
Insurer excused from indemnity where reliable evidence showed an unlicensed person drove the insured bus.
Insurance law – motor vehicle insurance – policy exception for vehicles driven by unlicensed persons – credibility of eyewitness and judicial inspection of vehicle – validity of PSV licence under Road Traffic Act.
21 September 2010
Failure to prove discrimination prevents a court from ordering an employer to sell company housing to employees.
Employment/housing — Alleged discrimination in employer sale of company houses — Burden of proof on alleging party — Offers accepted create contractual rights — Declaratory relief discretionary — Prior authority distinguishable where inducement/retaliation established.
21 September 2010
August 2010
Allegations of "clandestine meetings" were not defamatory; fair comment unavailable and balanced reporting justified publication.
Defamation — meaning of defamatory words — fair comment defence — repetition of allegations versus opinion — duty to inform and balanced reporting — verification of sources — apology and estoppel (not decided because non-defamatory).
26 August 2010
A non-unionized employee's redundancy entitlements are governed by the staff handbook and statutory minima, not a time-limited collective agreement.
Labour law – redundancy entitlements – staff handbook v. collective agreement; application of Statutory Instrument No. 2 of 2002; inclusion of allowances in salary; notice pay; damages for humiliation.
16 August 2010
Appellate court upheld conviction and confirmed a 20-year sentence after endorsing trial judge's credibility findings and sufficiency of evidence.
Criminal law – Aggravated robbery – sufficiency of evidence and credibility findings – recovery and identification of stolen property – appellate review of sentence; 20 years' imprisonment with hard labour confirmed.
11 August 2010
An alternate director lacked authority to sell company property and the buyers were not bona fide purchasers for value.
Company law – authority of directors (alternate directors) – ostensible/apparent authority – indoor management (Turquand) rule – limits where execution sale and lack of board resolution exist; Bona fide purchaser for value without notice – requirements; Pleading and proof of fraud – necessity of specific pleading and higher standard of proof; Interest – variation to average short-term deposit rate and thereafter Bank of Zambia rate.
6 August 2010
Licensee occupying employer housing was not a sitting tenant or eligible purchaser; bona fide purchaser entitled to possession and equitable use payment.
Property law – sitting tenant versus licensee; employee eligibility to purchase employer housing; effect of secondment and retrenchment on purchase rights; bona fide purchaser; mesne profits and equitable compensation for use; assessment by Deputy Registrar.
5 August 2010
June 2010
An ex‑parte foreign family order for return/wardship of children is not registerable under Zambia’s Foreign Judgments Act.
Foreign judgments — Reciprocal enforcement — Guardianship of infants excluded from registration — Requirement of finality and monetary award — Registration of ex‑parte family orders impermissible.
15 June 2010
Appeal dismissed where conflicting medical reports were not presented at trial, so court had no obligation to make an insanity finding.
Criminal law – Insanity/mental state – Section 167 Criminal Procedure Code – duty of trial court to make special finding only where evidence of insanity is adduced at trial; appellate relief not available where defence withdrew medical reports and did not call examining doctor. Murder – proof of malice aforethought without post-mortem – reliance on witness testimony and alleged confession.
13 June 2010
April 2010
Garnishee relief requires an attachable debt; trial judge properly refused leave to appeal costs where debt was disputed and discretion was rightly exercised.
Garnishee proceedings – attachable debt requirement – Order 49; Garnishee nisi – ascertainable debt vs. payment schedule; Costs – appeals against costs-only orders – Section 24(1)(d); Judicial discretion to grant leave on costs; Effect of disputed account and pending litigation on garnishee relief.
23 April 2010
Whether a treaty bank’s immunity shields commercial acts — court found misdirection and restored protection for the applicant.
International organisations' immunity; restrictive vs absolute immunity; jure imperii vs jure gestionis; express waiver requirement (SI No.123/1992); access to justice; interlocutory injunction to protect property pendente lite.
21 April 2010
March 2010
Applicant's wrongful-termination claim failed because he voluntarily applied for and accepted retirement under the statutory instrument.
Employment law – Retirement v retrenchment – Statutory Instrument No. 84 of 1997 – voluntariness of retirement application – clean hands/equity – entitlement to repatriation allowance.
4 March 2010
January 2010
An interlocutory injunction that effectively determines the substantive issue of party membership is impermissible.
Interlocutory injunctions — prohibition on deciding merits at interlocutory stage — declaratory relief vs interim relief — balance of convenience and irreparable harm — political party membership/expulsion.
7 January 2010