Supreme Court of Zambia - 2014

174 judgments

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174 judgments
Citation
Judgment date
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
A dream-based belief in witchcraft, without corroboration, does not qualify as an extenuating circumstance to avoid the death sentence.
Criminal law – Murder – Extenuating circumstances – Allegation of witchcraft and dreaming – Whether dreaming and waking unwell amount to mitigation – Section 201 Penal Code – Fact-specific inquiry required.
3 February 2014
Conviction quashed where identity lacked corroboration and voire dire failed to show the child understood duty to tell the truth.
Criminal law – Defilement – Corroboration of commission and identity – Circumstantial evidence requiring cogency – Child witness – Voire dire – Juveniles (Amendment) Act 2011 s122 – Understanding duty to tell the truth – Conviction quashed where identity uncorroborated and voire dire defective.
3 February 2014
Circumstantial evidence, recent possession and common purpose upheld convictions; aggravated robbery sentence upgraded to life imprisonment.
Criminal law – Circumstantial evidence and recent possession – sufficiency to support conviction; doctrine of common purpose/joint enterprise; appellant’s silence and failure to give evidence; admissibility and role of alleged admissions; sentencing – upgrade of aggravated robbery sentence to life imprisonment.
3 February 2014
The appellant's challenge to a 30-year sentence for defiling an intoxicated 14-year-old was dismissed; sentence affirmed.
Criminal law – Sentencing – Defilement of a child – statutory minimum sentence – appellate interference with sentencing discretion – mitigating effect of first offender status and mutual intoxication.
3 February 2014
January 2014
Whether the employer or another entity bore retrenchment liability and house-purchase rights — court held the club liable.
Employment law – employer identification – retrenchment liability – where a club remained direct employer after asset transfer, club (not former owner) liable for retrenchment benefits; sitting-tenant occupation alone does not confer right to purchase employer-owned houses.
29 January 2014
A court cannot extend the Arbitration Act's three‑month time limit to set aside an award; applications must be timely.
Arbitration Act s17(3) — three‑month time limit mandatory; 'may' construed as applicant's discretion not court's; substantive versus procedural law; Arbitration (Court Proceedings) Rules r38(1) limited; no court power to extend statutory limitation; finality and expedition in arbitration; delay inordinate and prejudicial.
29 January 2014
Court reduced excessive interim maintenance, quashed certain maintenance and rent orders, and upheld retrospective power under Matrimonial Causes Act.
Family law – maintenance pending suit – assessment of income and financial resources – inadmissibility of occasional parental assistance as appellant's income – maintenance awards must reflect proven earning capacity; maintenance orders may be retrospective under Matrimonial Causes Act s.52(2).
21 January 2014
Defamation requires pleaded words and meanings; Order 20 r.11 cannot be used to add substantive findings or awards.
Civil procedure – correction of judgment – Order 20 r.11 R.S.C. 1999 limited to clerical mistakes; Defamation – necessity of pleading specific words and meaning; False imprisonment – detention by police to assist investigations following a bona fide employer report not automatically actionable; Evidentiary rule – documents and reports must be produced to be relied upon in judgment.
20 January 2014
A certificate of title cannot be cancelled absent fraud; a sitting tenant’s priority does not defeat an innocent purchaser’s title.
Land law – Certificate of title conclusive (s.33 Lands and Deeds Registry Act) – Cancellation only for fraud or impropriety (s.34) – Bona fide purchaser for value – Sitting tenant’s priority not absolute – Court should join/subpoena employer to clarify offers.
19 January 2014
Appeal against assessment of personal injury damages dismissed except that interest must run from date of writ to judgment, then at BOZ rate.
Civil damages — assessment of personal injury damages — categorisation into pain and suffering, loss of amenities, permanent disability and special damages; admissibility of unpleaded consequential loss; evaluation of special damages where some receipts forged; interest on judgment — proper commencement (date of writ to judgment) and post-judgment rate (Bank of Zambia lending rate).
19 January 2014
Judicial review unavailable for private-law tender cancellation; trial judge erred in relying on a court-obtained tender document.
Administrative law — Judicial review — Leave requirement — Whether cancellation of a tender engaging private law/contractual rights is amenable to judicial review — Admissibility and propriety of a judge relying on a document not produced in evidence.
16 January 2014
Cancellation of a tender involving private contractual rights is not ordinarily amenable to judicial review; trial judge erred by relying on an unproduced tender document.
Judicial review — leave to apply — Order 53 Rules — tender cancellation; private law v public law; sufficiency of interest; inadmissibility of court-sourced evidence in ex parte proceedings; arguability threshold for leave.
15 January 2014
Respondent proved readiness to complete purchase; vendor could not repudiate without serving a notice to complete; appeal dismissed.
Contract of sale – specific performance of land sale – readiness and willingness to complete – service of notice to complete before vendor may repudiate – counterclaim sufficiency – time not of the essence – exclusion of cold room.
15 January 2014
Deputy Registrar misapplied contract and pension rules; matter remitted for reassessment using correct contractual and scheme calculations.
Employment law – retirement benefits – Conditions of Service (Clause 10.1.2) – gratuity payable three months per completed year; no pro‑rata; basis of calculation monthly salary not annualised. Pension law – ZSIC Pension Scheme – incorrect splitting of employee and employer contributions; apply scheme/manager’s one‑off calculation; assume timely remittance of contributions. Remittal for reassessment
10 January 2014
Whether alleged corrupt practices and church donations nullified the election; appellant failed to prove requisite grounds.
Electoral law – Section 93 Electoral Act – burden and standard of proof in election petitions – scope of Section 93(3) – candidate liability for acts of election agents – pleadings requirement – donations at churches and corrupt practice – assessment of witness credibility and demeanour.
9 January 2014
Withdrawal of an appeal without respondent's consent permits the respondent to seek costs under Rule 63(3).
Civil procedure – Withdrawal of appeal (Rule 63) – Consent required for dismissal by withdrawal – Non-consent permits application on costs – Costs to be taxed in default of agreement.
8 January 2014
Appeal dismissed: trial judge rightly found a case to answer and the applicant jointly participated in aggravated robbery.
Criminal law – Aggravated robbery – Case to answer (s.206 Criminal Procedure Code) – Credibility findings and appellate deference – Circumstantial evidence and inference of joint participation (Chimbini).
7 January 2014
Corroboration of identity may be established by independent circumstances and admissions; 35‑year sentence for defiling a three‑year‑old upheld.
Criminal law – Defilement – Requirement of corroboration as to both commission and identity – Corroboration may arise from independent circumstances, admissions and conduct; mere opportunity insufficient – Sentence appeal – 35 years for defilement of a three‑year‑old not excessive where aggravating factors present.
7 January 2014
Restriction on company property was reversed where investigations targeted a shareholder personally, upholding corporate separateness.
Anti-Corruption Act s24(1) – Restriction notices – Requirement of on-going investigation but not specification of offence; corporate personality – company property distinct from shareholders; scope of investigations relevant to validity of restriction notice.
6 January 2014
Circumstantial evidence of strangulation (fractured thyroid) established malice; conviction upheld and life sentence substituted with mandatory death.
Criminal law – Murder – Circumstantial evidence sufficiency; strangulation with fractured thyroid bone as evidence of malice aforethought (s.204(b)) – Intoxication (s.13(4)) requires evidence fit for a jury – Danger of false implication from relative witnesses – Proviso to s.15 Supreme Court Act – Substitution of sentence with mandatory death.
6 January 2014
Appellant liable for unpaid liquidator fees for itself and subsidiaries; appeal dismissed and costs awarded.
Company law – liquidator’s remuneration – Committee of Inspection approval – estoppel by conduct – court’s power to order payment where committee unreasonably withholds approval (Companies Act, s.321) – admissibility of time-sheets as evidence of work – waiver of procedural irregularity by participating in trial (Supreme Court Rules, Order 2).
6 January 2014
Restriction notices require ongoing investigations and must target the correct legal person given corporate separateness.
Anti-Corruption Act s.24(1) – Restriction notices – sufficiency of ongoing investigation; Corporate personality – company assets distinct from shareholders’ property; Valid target of restraint – necessity to direct notice at correct legal person; Court may examine scope of investigations to prevent misuse.
5 January 2014