Supreme Court of Zambia - 2019

184 judgments

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184 judgments
Citation
Judgment date
December 2019
Appellate court upholds trial judge’s equitable award under s13 and will not disturb factual findings absent perversity.
Sale of goods; tax receipts and evidence; equitable jurisdiction—Section 13 High Court Act; appellate review of findings of fact; abandonment of cross-appeal.
9 December 2019
Appellate court upheld trial judge’s factual findings and equitable award under section 13; cross‑appeal abandoned, costs to respondents.
Equitable jurisdiction – Section 13 High Court Act – law and equity administered concurrently; Appellate review of findings of fact – limited interference absent perversity; Money had and received / tax receipts – factual evaluation; Cross-appeal abandoned for failure to prosecute.
9 December 2019
9 December 2019
Appellants validly accepted varied fixed‑term contracts; no unilateral variation, duress, redundancy entitlement, or discrimination established.
Employment law – fixed-term/performance contracts – renewal at employer discretion – consent to varied written terms – economic duress not pleaded or proved – termination by effluxion of time, not redundancy – alleged nationality/age discrimination unsuccessful.
9 December 2019
Whether a suspect witness’s testimony requires corroboration and whether the appellant’s leading police provided ‘something more’ to uphold conviction.
Criminal law — suspect witness/accomplice — requirement for corroboration or ‘something more’ — evidence of accused leading police to others as ‘something more’ — misdirection and Section 15 proviso.
9 December 2019
Cogent circumstantial evidence can sustain murder and aggravated robbery convictions despite excluded child testimony and interpreter absence.
Criminal law – Circumstantial evidence – Cogency and inference of guilt; Juveniles Act s.122 – reception of child evidence; requirement of sign‑language interpreter when questioning speech‑and‑hearing‑impaired accused; aggravated robbery (s.294(1)) and murder – possession, violence and odd coincidences.
9 December 2019
Tenants have no automatic common law right of first refusal; any pre-emptive purchase right must be contractually granted.
Landlord-and-tenant law – distinction between option to purchase and right of pre-emption (first refusal); no common law right to first refusal absent agreement; trustees’ duty to beneficiaries and lawful disposal of trust property; protection of bona fide purchasers; inadmissibility of fraud not pleaded below.
9 December 2019
Arson conviction upheld on circumstantial evidence; forty-year sentence for a first offender reduced to fifteen years.
Criminal law — Arson — Circumstantial evidence: threats, presence at scene, and matches found — inference of guilt; Sentencing — first offender — manifestly excessive sentence reduced from 40 to 15 years.
9 December 2019
Appeal dismissed where the record omitted material documents and grounds of appeal were ambiguous or abandoned.
Civil procedure – Appeals – Grounds of appeal must be clear and disclose the error complained of (Rule 58(2)) – Record of appeal must include documents material to the appeal (Rule 58(4)) – Incomplete record may justify dismissal of appeal (Rule 68(2)) – Parties’ submissions are not evidence.
9 December 2019
Court held prison overcrowding and inadequate diet violated the right to life and constituted inhuman, degrading treatment; State must remedy conditions.
Constitutional law — justiciability of economic, social and cultural rights; right to life includes adequate nutrition and health care; prison conditions — overcrowding and poor sanitation amount to inhuman and degrading treatment; State obligation to provide special diets for prisoners with medical needs; enforcement via Prison Rules and constitutional remedies.
9 December 2019
A 35‑year manslaughter sentence for a first‑time offender who pleaded guilty was reduced to 10 years for being excessive.
Criminal law – Manslaughter – Sentencing – Weight of guilty plea, first‑time offender status and remorse in mitigation – Aggravating factors: intoxication, domestic violence and infant victim – Appellate interference where sentence is excessive, wrong in principle or induces a sense of shock – Consistency in sentencing.
9 December 2019
9 December 2019
9 December 2019
Conviction upheld where accused led police to a fresh struggle site; intoxication not extenuating, death sentence imposed.
Criminal law – murder – circumstantial evidence – corroboration of interested/suspect witnesses – leading of police by accused – fresh evidence from previously unknown struggle site – drunkenness and extenuating circumstances – sentencing (mandatory death).
9 December 2019
Whether "basic salary" includes allowances for terminal benefits — court held it excludes allowances.
Contract construction — "basic salary" v. "salary" — whether allowances form part of terminal benefits — where parties defined "basic salary" as starting salary in appointment letter, allowances excluded — no ambiguity; contra proferentum inapplicable.
9 December 2019
VAT refunds upheld where Coffee Act makes Association the sole exporter, rendering VAT Rule 18 inapplicable to growers.
Tax — VAT refunds; VAT Rule 18 — documentary proof of export; Coffee Act — Association as sole exporter; inconsistency of subsidiary rules with primary statute; tax administration and implementability; interest on tax refunds (short-term deposit rate to judgment, lending rate thereafter).
9 December 2019
Whether the respondent's termination for politically-charged statements amounted to wrongful, unfair, or unlawful dismissal.
Employment law - Termination v dismissal - Section 36(3) Employment Act (amended) - Valid reasons may relate to conduct or capacity - Section 26A limited to oral contracts - Reinstatement remedy considered
6 December 2019
An appeal challenging only factual findings is incompetent under Section 97 ILR Act; lower court's wrongful and unfair dismissal award upheld.
Industrial and Labour Relations — Appeal competence — Section 97 ILR Act — Appeals limited to questions of law or mixed law and fact — Findings of fact are not reviewable on appeal; wrongful and unfair dismissal; procedural fairness and committee constitution; damages in lieu of reinstatement.
6 December 2019
Appeal dismissed as incompetent because it exclusively attacked factual findings, leaving wrongful and unfair dismissal finding intact.
Industrial and Labour Relations Act s97 — appeals limited to questions of law or mixed law and fact — appellate inadmissibility of appeals challenging only findings of fact; wrongful and unfair dismissal; disciplinary procedure and committee constitution; damages in lieu of reinstatement.
6 December 2019
Guilty plea should be considered in sentencing; appellate court reduced an excessive arson sentence.
Criminal law — Arson — Sentencing — Role of guilty plea/remorse as mitigation — Appellate interference where sentence is wrong in principle or manifestly excessive — Mandatory minimum sentences.
3 December 2019
Appellate court reduced a manifestly excessive 20-year arson sentence to 11 years after finding sentencing errors.
Criminal law – Arson – Sentencing – Plea of guilty and remorse as mitigating factors – Appellate interference with sentence: wrong in principle, manifestly excessive, exceptional circumstances – Mandatory minimum sentences.
3 December 2019
Confession excluded for lack of reasoned trial-within-a-trial ruling, but reliable identification and possession upheld the conviction.
Criminal law – admissibility of confessions – trial-within-a-trial requires a reasoned ruling; Identification – single witness evidence and connecting links; Possession of stolen property as corroboration; Evidence of 'leading' police worthless if nothing new discovered.
3 December 2019
Possession of recently stolen property and related coincidences can make circumstantial evidence sufficiently cogent to sustain convictions.
Criminal law – circumstantial evidence – possession of recently stolen property and odd coincidences – hearsay exception for investigative narration – investigative omissions not necessarily fatal to prosecution.
3 December 2019
The High Court misdirected on sentence and a wrongful committal under s217 led to a reduction of a 14-year term to 2 years.
Criminal law – Attempted arson (s329 Penal Code) – Maximum sentence 14 years – Committal for sentencing by subordinate court (s217 Criminal Procedure Code) requires recorded reasons – Wrongful remittal and excessive sentence – Reduction of sentence to reflect subordinate court jurisdiction and absence of aggravating factors.
3 December 2019
November 2019
Appellant failed to prove respondent's mining/blasting caused property damage; appeal dismissed and trial findings upheld.
Property damage – alleged mining/blasting damage – causation and burden of proof; Appellate review of factual findings – limits and exceptions; Baseline structural survey and EIS/regulatory compliance; Egg‑shell‑skull principle – inapplicability where negligence not pleaded; Seismograph evidence and blast distances.
28 November 2019
Refusal to accept a lawful contractual transfer justified dismissal; redundancy and contractual remainder-pay claims failed.
Employment law – Transfer and disciplinary dismissal; Contractual terms permitting transfer; Unfair, wrongful and unlawful dismissal; Medical examination (s.34) applies to initial appointment not transfers; Redundancy vs transfer; Hearsay and appellate procedure; Enforceability of clause providing payment for remainder of contract where dismissal is for misconduct.
28 November 2019
28 November 2019
A plaintiff must plead and prove particulars of negligence; res ipsa loquitur cannot shift the burden onto the defendant.
Tort — Negligence; burden of proof in civil cases; res ipsa loquitur; admissibility of evidence from criminal investigations (not outcomes); requirement for pleaded particulars; contributory negligence (failure to insure).
27 November 2019
Joinder does not obviate the need to amend pleadings or adduce evidence; alleged pension scheme unproven, appeal allowed.
Joinder and representative actions – amendment of pleadings – duty to plead and prove individual claims; pension scheme establishment – need for terms, board resolution and statutory approval; perverse findings – appellate review; improper application of precedent on computation of terminal benefits.
27 November 2019
Appeal dismissed: procedural non-compliance and unjustified delay did not warrant extension of time to appeal.
Industrial Relations Court – application for leave to file complaint out of time – requirement to show good cause – Section 85(3) and proviso; Supreme Court Rules – Rule 58(2) on grounds of appeal; Section 97 (appeals on points of law/mixed law and fact); discretion to extend time; procedural compliance; duties of counsel.
19 November 2019
October 2019
An employee with superior allowances but no managerial authority was a "qualified clerk" entitled to statutory terminal benefits.
Labour law – Minimum Wages and Conditions of Employment (General) Order 2006 (SI No.57/2006) – definition of "qualified clerk" – management exclusion – superior conditions of service not determinative of management status – entitlement to terminal benefits and interest.
31 October 2019
Whether enhanced allowances converted the respondent into management, excluding him from minimum-wage protections.
Employment law — Minimum Wages and Conditions of Employment (General) Order, 2006 — classification of 'qualified clerk' vs 'management' — whether superior conditions convert a clerk into management — entitlement to statutory terminal benefits.
31 October 2019
29 October 2019
Mere suspicion is insufficient for slander per se; lawful police entry under s.19 CPC negates a trespass claim.
Defamation – slander actionable per se – requires direct imputation of crime, not mere suspicion; Trespass – police power under s.19 Criminal Procedure Code to enter premises when pursuing arrest – Article 17 rights subject to statutory exceptions; Presence of private person accompanying lawful police action does not automatically create trespass liability.
28 October 2019
Financial hardship alone, without material proof and alternatives exhausted, does not justify extension to file an appeal record.
Civil procedure — Extension of time to file record of appeal — Rule 12(1) — Insufficiency of funds does not automatically justify enlargement of time — Requirement for material evidence when exercising discretion — Duty to comply with procedural time limits; availability of legal aid.
23 October 2019
Appeal allowed: failure to prove the contested bottle’s origin and medical causation defeated negligence claim.
Product liability and negligence – duty of care of manufacturer – burden on claimant to prove manufacturer, contamination and causation – necessity to produce disputed bottle and call public analyst/medical witnesses – appellate interference with trial credibility findings where judge was wrong in principle.
23 October 2019
Failure to include material documents in the record of appeal is fatal; appeal dismissed under Rules 58(4) and 68(2).
Civil procedure — Record of appeal — Rule 58(4)(h) & (i) — omission of affidavits/documents and material papers (conditions of service, pension rules) — Rule 68(2) sanction — appeal dismissed — costs follow the event.
9 October 2019
Buyer’s failure to obtain vacant possession after purchase is governed by vendor–purchaser contract law, not the Rent Act.
Property law – vendor and purchaser v. landlord and tenant – Rent Act applicability – vacant possession after sale – remedies for breach of contract of sale (specific performance/damages) – jurisdiction to grant Rent Act relief.
9 October 2019
Whether a bank must bear loss from unauthorized online card transactions where it fails to exercise reasonable care securing the online channel.
Banking law – Online/ATM/Visa card fraud – Allocation of liability for unauthorized electronic transactions – Burden and standard of proof in civil claims – Bank’s contractual/common-law duty to secure online channels and exercise reasonable care.
8 October 2019
Notice termination lawful absent evidence of malice; redundancy finding and award set aside.
Employment law — Termination by notice/payment in lieu — Industrial Relations Court’s limited power to peer behind notice terminations — Redundancy: burden of proof that a post was abolished — Right to be heard on appraisal governed by employer’s grievance procedure.
8 October 2019
Termination by payment in lieu of notice upheld; redundancy award overturned for lack of supporting evidence.
:[
8 October 2019
Procedural ambush and unsupported allegations rendered the dismissal wrongful and unfair; damages reduced to six months' pay.
Employment law — disciplinary procedure and natural justice (audi alteram partem); wrongful dismissal (procedural irregularity); unfair dismissal (substance/reasonableness); measure of damages for dismissal; costs under IRC Rule 44(1).
8 October 2019
Interlocutory costs may be taxed forthwith under Order 62 Rule 8(9) where no further order concerning the interlocutory matter is anticipated.
Civil procedure — Costs — Taxation of interlocutory costs — Order 62 Rule 8(9) allows taxation forthwith where no further order is likely — Effect of party joining on immediate taxation of interlocutory costs.
4 October 2019
Where interlocutory proceedings have concluded with no further orders anticipated, costs may be taxed immediately under Order 62 rule 8(9).
Civil procedure – costs – taxation of interlocutory costs – Order 62 rule 8(9) allowing immediate taxation where no likelihood of further order – status as joined party does not preclude immediate taxation in such circumstances.
4 October 2019
September 2019
Conviction quashed where key witnesses gave inconsistent, uncorroborated evidence and one witness had a potential interest.
Criminal law — Identification and reliability of witnesses — Inconsistent testimony and witness with possible interest — Need for corroboration of suspect witness — Conviction unsafe where evidence is contradictory and uncorroborated.
26 September 2019
Damages for wrongful dismissal generally equate to notice-period pay unless claimant proves additional loss or special circumstances.
Employment law – wrongful dismissal – measure of damages ordinarily equivalent to notice period – enhanced awards only for special circumstances – proof of loss and mitigation – burden of proof on claimant to show additional loss; employer must plead and prove failure to mitigate.
26 September 2019
An officer of an unincorporated club is personally liable for club debts; execution against his goods was lawful.
Unincorporated associations – no separate legal personality – officers and members’ personal liability – agency defence inapplicable where principal does not exist – lawful execution against member’s goods.
19 September 2019
Officers of an unincorporated club are personally liable for debts; a disclosed principal must legally exist to avoid personal liability.
Unincorporated associations — no separate legal personality — officers/members personally liable for debts; agency — disclosed principal must exist; joint and several liability; execution against a member permissible.
19 September 2019
Employer’s invocation of payment-in-lieu was pierced as bad faith; downgrading amounted to redundancy entitling the employee to pay.
Employment law — redundancy — organisational review and downgrading of post — payment-in-lieu-of-notice may be pierced where employer acts in bad faith — entitlement to redundancy payment (equal treatment) — interest on award.
10 September 2019
Employer’s invocation of termination-by-notice to avoid redundancy pay was displaced where downgrading and lack of consultation showed true redundancy.
Employment law – redundancy – organisational review and downgrading of post – employer invoking payment in lieu of notice to disguise redundancy – court may look behind termination-clause where sufficient evidence suggests ulterior motive – variation of basic terms without consent deemed to terminate contract – entitlement to redundancy pay and comparable treatment.
10 September 2019