Supreme Court of Zambia - 2014

172 judgments

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172 judgments
Citation
Judgment date
May 2014
Government privatisation frustrated post‑employment hospital benefits; cash‑in‑lieu claim lacked contractual basis and appeal dismissed.
Contract law — frustration by governmental privatisation; separate corporate personality; foreseeability and self‑inducement; no contractual right to cash in lieu; evidential burden; Privatisation Act/Privatisation Revenue Account not creating direct company liability.
29 May 2014
27 May 2014
Appeal succeeds on pension computation: use ZSIC formula and apply 15% internal interest to retirement, then court interest thereafter.
Pension assessment – employer’s contributions – correct formula to be applied consistent with treatment of similarly situated employees – internal scheme interest applies only up to retirement – court-awarded interest applies after judgment (24% to judgment; 35% thereafter) – referral for reassessment.
23 May 2014
22 May 2014
Appellant unlawfully detained twice; employers held vicariously liable after trial judge’s factual misapprehension reversed.
Tort — False imprisonment/unlawful detention — Detention by private persons and police — Onus to justify detention once detention established — Employer vicarious liability for employees’/agents’ torts — Appellate interference where trial judge misapprehends pleadings and evidence.
22 May 2014
Parties cannot by consent overturn a court’s nullification of an MP’s election; candidate liable for treating and undue influence.
Election law – election petitions are public matters under Article 72 – parties cannot by consent set aside judicial nullification; candidate liability for corrupt or illegal campaign practices by persons acting with his knowledge or consent (apparent agents); treating and undue influence (distribution of money/goods, timing of benefits, threats) – limited application of s.93(3) – judicial discretion on taking judicial notice of other judgments.
18 May 2014
13 May 2014
11 May 2014
Tribunal lacked jurisdiction to continue proceedings after the applicant’s resignation was accepted; decision quashed and prohibited.
Judicial review – Tribunal jurisdiction under Article 98(3),(5) – Resignation under Article 137(2) – Illegality and excess of jurisdiction – Wednesbury unreasonableness – Certiorari and prohibition granted.
8 May 2014
Failure to fully comply with an 'unless' order leads to dismissal; partial compliance does not regularise an appeal.
Civil procedure – 'unless' orders – failure to comply results in dismissal; partial compliance insufficient; irregular steps remain irregular until cured by application; motion to dismiss for want of prosecution properly entertained when brought before restoration.
4 May 2014
1 May 2014
1 May 2014
1 May 2014
April 2014
Whether a sitting government employee could purchase a parastatal-owned house when a prior valid sale to another existed.
Property law – Parastatal house sales – Eligibility under Government home ownership empowerment scheme – Sitting tenant status versus nexus to selling parastatal – Validity and priority of competing contracts of sale – Remedy of refund where later sale nullified.
29 April 2014
Procedural defects — improper transfer and lack of fresh pleadings — matter remitted for retrial before another High Court judge.
Civil procedure — Subordinate Courts Act s.20(1) — magistrate lacks power to transfer for want of jurisdiction — proper remedy dismissal — High Court misdirection in hearing matter without fresh pleadings — procedural irregularities vitiating trial — lease disputes; counter-claim for compensation; costs follow the event, but no costs on appeal.
28 April 2014
Application for certiorari dismissed: Committee lawfully exercised statutory suspension powers; no procedural unfairness or jurisdictional error.
Administrative law – judicial review of professional disciplinary decision; jurisdiction and statutory power to suspend practising certificate; functus officio and res judicata; Wednesbury unreasonableness; natural justice and procedural fairness; exhaustion of administrative remedies.
24 April 2014
Dismissal for organising a union meeting on mine premises without management consent was lawful and justified.
Labour law — disciplinary dismissal — non-compliance with established procedures (Clause 3.2(h)) — Mining Regulations (402, 407) — union rights conditional on employer/supervisor consent — workplace safety and order.
14 April 2014
The applicants’ dismissal for organising an unauthorised workplace union meeting was upheld under mining and disciplinary regulations.
Employment law – disciplinary dismissal – organising unauthorised workplace union meeting – non‑compliance with established procedures (Clause 3.2(h)).
13 April 2014
Appeal against indecent assault conviction dismissed; conviction upheld and sentence amended to 15 years with hard labour.
Criminal law – Indecent assault of a child – Credibility and corroboration of child and relative witnesses – Medical report admissibility – Suspect witnesses – Flight as corroboration – Sentencing: substitution to hard labour.
8 April 2014
Conviction for armed robbery upheld despite no ballistics expert where witnesses saw guns and cartridges were recovered.
Criminal law – Armed robbery – Necessity of ballistics expert evidence – Empty cartridges recovered at scene – Eyewitness identification of firearms – Corroboration by recovered stolen property – Conviction safe without expert matching where no firearm recovered.
8 April 2014
Recognition by relatives sufficed; prolonged collective assault established malice aforethought; death sentence upheld.
Criminal law – identification by recognition – related witnesses – corroboration not required where recognition in broad daylight is reliable; Murder – malice aforethought under s.204 – prolonged, collective assault, confinement and use of weapons can establish intent to cause grievous harm or death; Sentencing – extenuating circumstances must be provable; suspicion of theft does not mitigate deliberate torture.
8 April 2014
Court upheld indecent assault conviction despite related witnesses, substituting simple imprisonment with hard labour.
Indecent assault — credibility of relative witnesses — corroboration by circumstantial evidence and child-witnesses — admissibility and weight of medical report — allegations of coerced testimony — sentencing substituted to imprisonment with hard labour.
7 April 2014
Court upheld convictions based on reliable identification, recent possession and circumstantial evidence despite absent fingerprints and counsel.
Criminal law – Identification evidence; single/multiple witnesses; recent possession and circumstantial evidence – Proof beyond reasonable doubt – Investigative dereliction – failure to lift fingerprints – Fair trial – right to legal representation under Article 18 – proceeding in absence of counsel – murder and aggravated robbery.
7 April 2014
Single-witness identification corroborated by victim's discovery of appellant's belongings upheld; murder conviction affirmed, attempted murder sentence increased.
Criminal law – Identification evidence – Single-witness identification requires corroboration – Corroboration by belongings found at scene – Murder and attempted murder – Sentence variation.
7 April 2014
Conviction overturned for lack of corroboration and a defective voire dire under the amended Juveniles Act.
Criminal law — Defilement — Corroboration of child witness identification — Juveniles (Amendment) Act No. 3 of 2011 s122 — Defective voire dire — Medical report corroborates commission but not identity — Conviction unsafe without corroboration.
7 April 2014
Circumstantial evidence, possession and forensic ballistics linked the appellant to armed robberies; appeal dismissed.
Criminal law – Aggravated robbery – Circumstantial evidence and possession — Leading police to recovery — Prosecution’s duty to call witnesses — Suspect witnesses — Ballistic expert evidence and definition of firearm under Firearms Act.
7 April 2014
Security for costs cannot be imposed to stifle a defendant compelled to defend or obstruct access to justice.
Security for costs – Order 40(7) HCR and Order 23 RSC – security against defendant only for proceedings in his interest – discretion and factors to consider – excessive security and access to justice – duplicity of proceedings and procedural conduct.
1 April 2014
March 2014
Dismissal for soliciting a bribe upheld; procedural irregularities immaterial where misconduct proven.
Disciplinary law — dismissal for bribery/corruption — procedural fairness — internal disciplinary procedure non-compliance — appellate review of factual findings.
20 March 2014
Assessment of damages must be based on available audited financial evidence; unsupported and duplicative awards are remitted for reassessment.
Civil procedure – assessment of damages – reliance on bank statements versus audited financial statements; special damages and need for particularisation; loss of use and loss of profit; mitigation of unjust enrichment; remittal for reassessment; discounting interest already paid.
17 March 2014
Restoration denied: mandatory filing rules fatal to appeal; counsel’s default or party’s presence did not justify restoration.
Civil procedure – restoration of appeal – Rules 48(5) and 71(2) – Rule 48(5) applies to full bench – mandatory filing (Rule 58(5), Rule 70(1)) – failure to file heads fatal – party present cannot claim absent – counsel’s negligence not ground for restoration; Affidavits – extraneous legal argument expunged under Order 41/5/1.
13 March 2014
Corroborated child testimony and an ‘odd coincidence’ in the appellant’s account upheld the defilement conviction; appeal dismissed.
Criminal law – Defilement of a child – Corroboration required as to commission and identity – Child witness evidence – Dangers of false implication – Emmanuel Phiri: special and compelling grounds – Unsigned/unsworn statement as corroborative coincidence.
9 March 2014
A 30-year sentence for defilement of a 12-year-old upheld; sentencing judge properly exercised discretion and considered mitigation.
Criminal law – defilement — sentencing range 15 years to life — factors: victim’s age, manner of attack, offender’s plea and antecedents — appellate interference only if discretion misapplied or sentence shocks conscience.
9 March 2014
Appeal dismissed: recognition evidence found reliable and honest mistake excluded, conviction and death sentence upheld.
Criminal law — Murder; identification evidence — recognition of a known person; identification parade; risk of mistaken identification; circumstances (moonlight, prior acquaintance, physical struggle) can render recognition reliable.
9 March 2014
Appeal dismissed; indecent-assault conviction upheld and sentence increased for abuse of authority.
Criminal law – indecent assault – consent and corroboration – competence of witness and voire dire – medical evidence corroboration – belief in consent defence – sentencing: aggravation for abuse of authority.
9 March 2014
Recent possession of stolen items and corroborating evidence upheld aggravated robbery convictions; appeal dismissed.
Criminal law – aggravated robbery – recent possession of stolen property – inference of guilt – identification evidence – record of proceedings versus judgment for appeal – requirement of a verdict before conviction.
9 March 2014
Appeal dismissed: evidence did not justify considering diminished responsibility, conviction and sentence upheld.
Criminal law – murder – diminished responsibility – duty to consider unraised defence only where evidence fit to be left to a jury – burden on defence to prove diminished responsibility on balance of probabilities – appellant’s coherent account inconsistent with diminished responsibility.
9 March 2014
Appeal dismissed: child witnesses' voire dires were properly conducted and there was sufficient corroboration for conviction.
Criminal law — Defilement — Corroboration of child complainant and identity of offender; Juveniles Act s.122 — procedure for voire dire; admissibility and oath of child witnesses; appellate deference to trial court credibility findings.
9 March 2014
Appeal against convictions for aggravated robbery and murder dismissed; suspect witness required corroboration which the Court found satisfied.
Criminal law – aggravated robbery and murder – circumstantial evidence – suspect witness requiring corroboration – identification parade – recent possession and demonstrative leading evidence – appeal dismissal.
9 March 2014
February 2014
Members of a contributory pension scheme are entitled to an accounting of accrued contributions; penal interest is unlawful and substituted.
Pension law – contributory occupational pension scheme – members’ and employer’s contributions belong to members – entitlement to account of accrued values at separation – single scheme with different fund managers – leaving service options (Rule 11) – penal interest unlawful; substituted interest award.
25 February 2014
Appeal allowed: midwife’s failure to secure emergency measures was negligent; dismissal and house withdrawal were lawful.
Employment law; medical negligence – duty of care of nurses/midwives; standard of care objective test; administrative policy versus clinical discretion; entitlement to government housing as incident of employment and withdrawal of allocation prior to acceptance.
18 February 2014
Unilateral repeal of ex-gratia entitlement cannot retrospectively deprive pre-existing employees of an accrued right without their consent.
Employment law – accrued rights – unilateral variation of terms – ex-gratia payment under Conditions of Service – retrospective application and employee consent.
17 February 2014
Baggage allowance payable at each tour’s end; expunged exhibits inadmissible; assessment remitted for recalculation.
Employment contracts – baggage allowance payable on completion of each tour – relevance of Circular B303/1965 for air freight baggage assessment; inadmissibility of expunged exhibits; improper reopening via supplementary affidavit (rebuttal evidence).
13 February 2014
Appellant failed to prove unreasonable behaviour or irretrievable breakdown; appellate court upholds trial judge's factual findings.
Family law – Divorce – Irretrievable breakdown – Unreasonable behaviour as ground for divorce – Appellate review of trial judge’s findings of fact; weight of conduct and cohabitation.
12 February 2014
Application to file notice of appeal out of time dismissed for inconsistent, afterthought reasons and lack of sufficient cause.
Civil procedure — Extension of time under Rule 12(1) — Notice of appeal out of time — Credibility and consistency of affidavit evidence — Afterthoughts and missing court record — Practice of single Judge sitting on full Bench.
11 February 2014
Employment contracts entitle teachers to baggage allowance at end of every tour; evidentiary errors require reassessment.
Employment contracts – interpretation of Clause 1 and Clause 7(3) – baggage allowance payable on expiration of every tour; Circular B303 (1965) applicable to baggage assessment; inadmissibility of expunged exhibits; improper admission of non-rebuttal evidence; findings unsupported by evidence set aside.
11 February 2014
Circulars that in practice withdraw a registered collective-agreement benefit unlawfully vary employees’ contractual conditions and are invalid.
Labour law – collective agreement – unilateral variation by employer via circulars – alteration/withdrawal of conditions of service; interpretation of "on official duties" in car allowance clause; High Court jurisdiction over individual employment claims.
11 February 2014
A licensed customs agent is liable for false declarations; natural justice may be displaced where statutory remedies and circumstances make prior hearing unnecessary.
Customs law — agent’s duty to verify and declare goods; sections 21(1)(b), 140, 183(1) Customs and Excise Act — administrative law — scope of judicial review; natural justice — circumstances displacing audi alteram partem; penalties and statutory appeals (ss.155, 190).
10 February 2014
Court reinstated appeal where applicants' delay was not inordinate and there was no malafide, granting 14 days to lodge record.
Civil procedure — appeal — dismissal for want of prosecution; extension of time under Rule 12; duty to lodge record of appeal; bona fide delay due to settlement negotiations; precedent — Nahar Investments v Grindlays; Stanley Mwambazi v Morester Farms.
10 February 2014
Employer’s circulars unlawfully altered a collective-agreement car allowance entitlement; appeal dismissed with costs.
Employment law – Collective agreement – Unilateral variation of conditions of service – Car allowance under Clause 32(f) – Meaning of "on official duties" – Administrative controls versus withdrawal – Jurisdiction of High Court over master-and-servant disputes.
10 February 2014
Omission to warn about relatives' false implication not fatal where unchallenged conduct corroborated appellant's guilt.
Criminal law – murder; identification evidence – courtroom recognition vs identification parade; danger of false implication by relatives; corroboration by appellant’s conduct on apprehension ('something more').
3 February 2014