Supreme Court of Zambia - 2014

174 judgments

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174 judgments
Citation
Judgment date
December 2014
Interpretation of SC Rules 49(2) and 49(5): filing within 30 days and serving notice with memorandum within 14 days.
Civil procedure – Supreme Court Rules 49(2) and 49(5) – Interpretation after 2012 amendment – Filing notice of appeal within 30 days; lodging and serving notice with memorandum within 14 days – Jurisdiction and competence of appeal.
29 December 2014
18 December 2014
Whether mandatory interlocutory relief can prevent implementation of disputed party resolutions and restore a suspended party president pending suit.
Interlocutory injunctions — requirement to define parameters — application of American Cyanamid principles — mandatory vs prohibitory injunctions — appellate discretion to consider arguments beyond lower court/memorandum — internal party disputes and suspension.
18 December 2014
Appeal allowed: appellate court granted mandatory interim relief restoring the suspended party president and restrained implementation of contested resolutions.
Civil procedure — interlocutory injunctions — requirements (serious question, irreparable injury, balance of convenience, clean hands) — scope and parameters of relief; appeal — admissibility of arguments not fully developed below or beyond memorandum of appeal; mandatory vs prohibitory injunctions — restoration pending determination; appellate power to grant relief.
18 December 2014
15 December 2014
9 December 2014
9 December 2014
Group attack causing injuries justified a 20‑year aggravated robbery sentence; appeal against sentence dismissed.
Criminal law – Aggravated robbery – Sentence – Whether sentence excessive – Group attack and grievous harm as aggravating circumstances – First offender – Appeal against sentence – Notice of appeal without grounds; failure to file Heads of Argument.
3 December 2014
2 December 2014
Circumstantial evidence and common design sufficed to convict; appellate court upheld conviction after rejecting the defence explanation.
Criminal law – Circumstantial evidence – Requirement of cogency permitting only inference of guilt; Common design and parties to offence (Sections 21, 22 Penal Code); Burden of proof and accused’s explanation – credibility assessment; Appellate deference to trial judge on credibility findings.
2 December 2014
2 December 2014
November 2014
Res ipsa loquitur justified finding appellant negligent for a broken needle that injured the respondent.
Medical negligence; res ipsa loquitur; burden shifts where circumstantial evidence shows foreign body after clinical procedure; expert evidence as guide not conclusive; duty to refer and standard of care in nursing and clinical treatment.
20 November 2014
A mortgagor’s unquantified counterclaim does not defeat a mortgagee’s right to possession; stay of execution discharged.
Mortgage law – Mortgagee’s right to possession – Counterclaim or equitable set-off does not ordinarily defeat possession – Court’s equitable discretion to postpone possession only where mortgagor can pay within reasonable time – Stay of execution discharged where set-off unquantified and appeal lacks prospects.
19 November 2014
The respondent was justified in summarily dismissing the applicants for refusing to attend an investigation.
Employment law – Summary dismissal – Contractual approach – Disobedience/insubordination as ground for dismissal – Conditions of Service/disciplinary code not engaged where no formal charge – Admissibility and weight of unpleaded Audit Report – Appellate restraint on findings of fact.
17 November 2014
October 2014
Provisional liquidators are usually paid from company assets, but courts may refuse payment where the winding-up petition was abusive or statute-barred.
Companies Act s285; Companies (Winding-Up) Rules r8(6) — provisional liquidator remuneration and expenses — court's discretion where petition fails or is rescinded — assessment requires detailed, itemised justification; abuse of winding-up proceedings; refusal to make company pay where petition is vexatious or statute-barred.
31 October 2014
Court allowed appeal: provisional liquidator ordinarily entitled to fees from company assets, but court may refuse payment where petition is an abuse and quantum must be properly assessed.
Companies law — provisional liquidator remuneration — s.285 Companies Act; Companies (Winding-Up) Rules r.8(6) — entitlement to fees from company assets — court discretion where petition fails or is abuse of process — requirement for itemised assessment and proof of expenses.
31 October 2014
Whether Registrar application is prerequisite to cancelling title, proper procedure for caveat removal, and who bears amendment costs.
Lands and Deeds Registry Act s.11 – administrative correction by Registrar is not a precondition to judicial cancellation of title; Certificate of Title – conclusive but challengeable for fraud; Caveat removal – ordinarily by originating summons but may be included in writ when part of broader action; Costs – amendment necessitated by plaintiff's omission attracts costs against that party; Leave to appeal on costs required only where appeal is solely on costs.
30 October 2014
The appellant could reject an unmerchantable printer despite repairs and warranty; four months' use did not forfeit the right.
Sale of Goods Act s14(2) – implied condition of merchantable quality – buyer’s statutory right to reject – effect of express warranty and repairs on rejection – reasonable time/acceptance by conduct.
30 October 2014
EIA consultation rights are not limited to title-holders; project approvals and remedial consultations justified dismissal of the appeal.
Environmental law – EIA process and public consultation; locus standi not confined to title-holders; admissibility and weight of expert evidence; mining licence/outsourcing; Ministerial suspension and legitimate expectation; procedural compliance for change of land use.
30 October 2014
A Supreme Court remittal to the High Court does not require recommencement by originating process under Order VI.
Civil procedure — Supreme Court remittal under s.25(1)(b)(iv) — No requirement to file fresh originating process — High Court may give directions for pleadings — Remitted matter not converted into an appeal by cause number or record filing.
30 October 2014
Deposit of title deeds created an equitable mortgage securing beer-credit; debt apportioned equally between the appellant and the 1st respondent.
Companies law – holding oneself out as director (Companies Act s.203(3)) – equitable mortgage by deposit of title deeds – deposit can secure third-party debt – joint business venture and joint liability for credit facility – apportionment of counter-claim debt; interest ordered from counter-claim date to judgment at short-term deposit rate then lending rate.
30 October 2014
Whether non-parties to a bank guarantee can challenge payment absent privity or a written demand.
Bank guarantees; suretyship and privity; condition precedent; written demand under a guarantee; locus standi to enforce guarantees; pleadings and particulars for negligence; Statute of Frauds (naming parties).
28 October 2014
22 October 2014
A bank’s third‑party mortgage was set aside for failing to guard against undue influence and for insufficient evidence of a valid deposit of title deeds.
Banking/security law – third‑party equitable mortgage by deposit of title deeds – possession alone insufficient to create charge; creditor on inquiry where borrower and surety are related – duty to guard against undue influence, ensure understanding and recommend independent legal advice – inference of fraud permitted from affidavit denials when particularity lacking.
22 October 2014
22 October 2014
16 October 2014
14 October 2014
Convictions affirmed where recent possession, leading evidence and re-enactments excluded danger of false implication.
Criminal law – aggravated robbery and murder – circumstantial evidence – suspect witnesses and corroboration – recent possession of stolen property – leading and re-enactment evidence – common purpose liability – sentencing of juvenile.
14 October 2014
13 October 2014
Psychiatric treatment receipts alone do not establish insanity; credible eyewitness testimony sufficed to uphold conviction.
Criminal law - Unnatural offence (s155 Penal Code) - requirement to prove sex against the order of nature; Criminal procedure - fitness to make a proper defence (s160 Criminal Procedure Code) - when psychiatric inquiry required; Evidence - eyewitness identification and corroboration; Standard - proof beyond reasonable doubt.
13 October 2014
13 October 2014
13 October 2014
12 October 2014
7 October 2014
5 October 2014
September 2014
29 September 2014
29 September 2014
29 September 2014
25 September 2014
23 September 2014
23 September 2014
23 September 2014
18 September 2014
18 September 2014
Only reliefs expressly provided for under the Landlord and Tenant (Business Premises) Act may be commenced by Originating Notice of Motion.
Landlord and Tenant (Business Premises) Act – mode of commencement – Originating Notice of Motion limited to applications expressly provided for by the Act – claims for declarations and damages require Writ of Summons – Apollo Refrigeration Services principle – deeming proceedings inappropriate where it leads to irrational result.
16 September 2014
7 September 2014
2 September 2014
Earlier valid allocation and payment confer ownership despite non‑occupation; limitation defence waived if not raised below.
Property law — Government pool housing allocations — Civil Service Home Ownership Scheme eligibility (bona fide sitting tenant) — Competent authority to allocate — Limitation defence waiver — Typographical errors in property descriptions and rectification of title.
1 September 2014
August 2014
A dismissal for inactivity under Order 53 Rule 12 does not bar a fresh action absent an adjudication on the merits.
Commercial Court Rules (Order 53 Rule 12) — dismissal for 60 days inactivity — effect of dismissal; res judicata; finality of litigation; directory vs mandatory rules; right to commence fresh action where no adjudication on merits.
21 August 2014
Applicant’s bid to impeach a final judgment for alleged ministerial error was an abuse of process and was dismissed.
Civil procedure – finality of judgments – impeachment for fraud – fraud exception narrow and strictly proved; abuse of process through repetitive litigation; Order 20 Rule 11 (White Book) invoked but inapplicable where evidence was available at trial.
21 August 2014