Supreme Court of Zambia - 2019 May

13 judgments

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13 judgments
Citation
Judgment date
May 2019
Whether a pay‑slip gross‑up for tax creates an accrued contractual service‑allowance right for computing retirement benefits.
Employment law — service allowance — whether pay‑slip grossed up for tax creates accrued contractual entitlement — employer grossing up to cushion tax does not alter contractual percentage used to compute terminal benefits; appellate review of perverse or misapprehended factual findings.
29 May 2019
High Court retains concurrent jurisdiction to hear counterclaims challenging re-entry, cancellation and renumbering of land despite Lands Act provisions.
Lands Act ss.13(3) & 15(1) – High Court and Lands Tribunal have concurrent jurisdiction; certificate of re-entry; cancellation and renumbering of title; jurisdictional objections; allegations of fraud; section 34 Lands and Deeds Registry Act – remedy for irregular repossession.
28 May 2019
High Court retains concurrent jurisdiction with Lands Tribunal; fraud allegations permit land disputes to be tried in High Court.
Lands Act – sections 13(3) and 15(1) – permissive jurisdiction; High Court and Lands Tribunal have concurrent jurisdiction in land disputes; allegations of fraud justify High Court proceedings; jurisdictional objections may be raised at any stage.
28 May 2019
Whether statutory minimum wages/allowances apply and if appellants, not being casuals, were entitled to allowances and notice pay.
Employment law – definition of ‘casual employee’ – continuous service exceeding six months removes ‘casual’ status; Minimum Wages and Conditions of Employment (S.I. No. 2 of 2011, as amended) – applies to casual and other workers and creates enforceable entitlements for ‘General Worker’; wrongful termination – notice pay as remedy; interest and costs for failure to defend/unreasonable delay
28 May 2019
A Certificate of Title is conclusive; absence and an unmeritorious counterclaim do not justify setting aside judgment.
Land law – Certificate of Title – s.33 Lands and Deeds Registry Act – conclusive evidence of ownership; Civil procedure – judgment in absence – Order 35 rr.3 & 5 – setting aside requires sufficient cause and a meritorious defence; Service of hearing notice; Counterclaim based on letter of offer insufficient against registered title.
28 May 2019
Public-law relief (declarations/mandamus) requires judicial review; wrong originating process rendered High Court judgment void.
Road Traffic Act s.13 (consultation of absolute owner) – breach of statutory duty – tort remedy for breach of statutory duty – judicial review required for ultra vires/mandamus relief – jurisdictional consequences of wrong originating process (writ v. Order 53)
28 May 2019
Public‑law relief alleging ultra vires actions and mandamus must be sought by judicial review, not by writ of summons.
Road Traffic Act s13 – duty to consult registered absolute owner before transfer; Judicial review v. writ of summons – jurisdictional limits; Breach of statutory duty – private tort remedy; Sheriff’s sale and title acquisition; Nullity of judgment for wrong originating process.
28 May 2019
Whether separate monetary remedies may be awarded for the same loss where dismissal is both wrongful and unfair.
Employment law – wrongful and unfair dismissal – procedural breaches of disciplinary code; substantive reasons unproven; remedy – single consolidated award for one compensatory event; procedural compliance and ex parte judgment; discretionary sale of personal-to-holder vehicle; contractual benefits following summary dismissal.
28 May 2019
Repeated unauthorised overdrafts and deposits constituted dishonest conduct justifying summary dismissal despite procedural irregularities.
Employment law – disciplinary procedure – repeated unauthorised overdrafts and unauthorised deposits – dishonest conduct – scope of judicial review of employer disciplinary decisions – procedural irregularities not necessarily fatal where misconduct admitted.
23 May 2019
Court upheld rape conviction finding sufficient corroboration and increased sentence from 20 to 35 years imprisonment.
Criminal law – Rape – Identification evidence and corroboration – Holistic assessment of witness identification (moonlight, prior acquaintance, opportunity and appellant's admissions) – Appellant's admissions as corroboration – Sentencing – aggravated circumstances and appellate increase of term.
21 May 2019
Leave to appeal refused: domestic property dispute did not raise a point of law of public importance.
Leave to appeal — Court of Appeal Act s.13(3) — point of law of public importance — scope of Supreme Court leave — property adjustment disputes are generally non-public issues — Practice Direction No.1 of 2002 — requirement to cite Act, section, rule or order — procedural irregularity and competence of application.
17 May 2019
Applicant's request to extend time to file a labour complaint denied for inordinate delay and insufficient explanation.
Industrial & Labour Relations Act s85(3) - extension of time to present complaints; Rule 47 not substitute for statutory proviso; Limitation Act inapplicable where statute prescribes period; inordinate delay; need for plausible explanation and exhaustion of administrative channels; discretionary nature of leave to file out of time.
16 May 2019
An employer may lawfully dismiss where a reasonable investigation yields a substratum of facts, and courts must not retry disciplinary findings.
Employment law – wrongful dismissal – substratum of facts required to support disciplinary dismissal; standard of proof lower than criminal standard. Procedural fairness – employer's investigation and opportunity to respond sufficient; disciplinary process not equivalent to criminal trial Evidence – failure by employee to answer specific allegations may justify adverse inference. Role of appellate courts – must not retry disciplinary decisions but assess reasonableness of employer's conduct
15 May 2019