Supreme Court of Zambia - 2019

184 judgments

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184 judgments
Citation
Judgment date
September 2019
Termination signed by the employer’s director valid despite shareholder letterhead; damages limited to notice; statutory leave pay upheld.
Employment law – termination – corporate agency and authority – shareholder letterhead vs director’s act; measure of damages for loss of employment – common law notice period; leave entitlements under oral contracts – s.15(1)(i) and employer record-keeping obligation.
10 September 2019
Certificate of title upheld; appellant not bona fide purchaser and ordered to yield possession and demolish structures; appeal dismissed.
Land law; certificate of title; conclusive but impeachable for fraud or impropriety; bona fide purchaser without notice; ineffective revocation by local authority; payments and issuance of title superseding withdrawal; unlawful structures and demolition; remedy against state officials for misleading conduct.
10 September 2019
An appeal was dismissed with costs due to a materially defective record of appeal and the appellant's decision not to appear.
Civil procedure — Record of appeal — Rule 58(4) — Incomplete/missing affidavits and documents — Record unsafe — Rule 68(2) dismissal; Rule 69 notice of non-appearance — risk of forfeiting opportunity to remedy defects.
9 September 2019
Appellant failed to prove economic duress; second signed contract superseded the first and appeal dismissed.
Employment law – variation of contract – second contract superseding earlier contract – economic duress – tests for duress (protest, alternatives, independent advice, steps to avoid) – appellate review of findings of fact (Nkhata/Achiume) – appointment notice as administrative payroll procedure.
9 September 2019
Corrected second employment contract superseded the first; no economic duress proved; appeal dismissed.
Employment law – variation of contract by second contract – economic duress (proof, Pao On factors, affirmation) – appointment letter as administrative payroll device – appellate review of factual findings (Nkhata/Achiume).
9 September 2019
Subordinate Court lacked jurisdiction to grant forfeiture restraining order exceeding its civil monetary limit.
Jurisdiction – Subordinate Courts – Forfeiture of Proceeds of Crime Act – civil proceedings – monetary limits – lack of jurisdiction renders proceedings a nullity.
9 September 2019
August 2019
Appeal dismissed for six appellants; fourth appellant's dismissal wrongful and awarded 24 months' salary.
Employment law – dismissal – summary dismissal justified where employee committed a dismissible offence despite procedural non‑compliance; union activity protection does not cover riotous or dishonest mobilisation – wrongful dismissal where charge letter lacks particulars – remedy ordinarily notice pay but enhanced damages may be awarded.
26 August 2019
Sale by a beneficiary without letters or court authority is void; appellant not a bona fide purchaser.
Intestate Succession Act (ss.19,24,38,43) – jurisdiction of local courts in succession matters – sale of estate property – requirement of letters of administration and prior court authority – bona fide purchaser and due diligence – caveat disputes and onus of proof.
26 August 2019
Court upheld a 45-year sentence for repeated defilement of a 14-year-old stepdaughter, finding no grounds to reduce.
Criminal law – Defilement – Sentence – Appeal against sentence – Appellate test: wrong in principle; manifestly excessive/inducing shock; exceptional circumstances – Aggravating factors: victim aged 14; step-parent relationship; repeated offences; resulting STI; occurrence at home – 45 years upheld.
19 August 2019
Circumstantial and postmortem evidence upheld a murder conviction despite absence of the pathologist's oral testimony.
Criminal law – murder – circumstantial evidence; malice aforethought – sufficiency of inferences; postmortem evidence – desirability but not always mandatory to call pathologist (s.191A); warn-and-caution statements – requirement for vernacular and English versions.
19 August 2019
Conviction for defilement quashed due to defective voire dire, lack of corroboration, and failure to discharge the prosecution's burden.
Criminal law — Defilement; child witness — requirements for voire dire and record of questions/answers; corroboration in sexual offences — identity evidence and 'something more'; burden of proof — prosecution's duty to disprove defences and to call material witnesses; court-ordered medical evidence.
19 August 2019
Conviction for defilement quashed where voire dire was defective, corroboration lacking and burden wrongly shifted to accused.
Criminal law – defilement – voire dire must record questions and answers – corroboration of identity and early complaint – prosecution's duty to call material witnesses – improper shifting of burden when accused requests medical examination.
19 August 2019
Confessions must be shown voluntary before admission; excluding them, independent evidence sustained four convictions while the fifth appellant was acquitted.
Criminal procedure – Admissibility of confessions – Trial court’s duty to test voluntariness and to invite defence objection; Evidence – Use of co-accused confession to implicate another – adoption and admissibility; Electronic evidence – phone activity reports as circumstantial linkage; Procedure – nolle prosequi where accused dies before close of prosecution.
19 August 2019
Appellate court upheld murder conviction based on credible civilian eyewitnesses and inferred malice aforethought.
Death in custody – credibility of civilian versus police witnesses – danger of false implication – corroboration and assessment of bias – medical evidence on head injury – inference of malice aforethought; appellate restraint on trial judge’s credibility findings.
13 August 2019
Former employees were not to be deemed retired at 55 by the Repeal Act; benefits owed were for years actually served, plus three months' pay in lieu of deficient notice.
Statutory interpretation – Repeal Act Section 8(2)-(3) – retirement under existing terms of service; Employment law – calculation of terminal benefits – pay for years served vs. pay for unworked years (unjust enrichment); Contractual notice – six months’ notice required, remedy salary in lieu; State proceedings – post-judgment interest ceiling.
9 August 2019
Court held non-compliance with an 'unless order' excused where parties were unaware due to missing record and lack of notification.
Civil procedure — extension of time to comply with 'unless orders' — discretion to extend time — contumelious or intentional non-compliance — effect of missing record and lack of service/notification.
8 August 2019
Section 47 applies to land reservation claims under the Public Roads Act; appellant failed to prove nuisance, damage or loss causally linked to roadworks.
Public Roads Act s47 – scope limited to compensation for loss of land/rights from road reservation under ss44–45; Tort – liability of statutory agency for nuisance, damage and loss of access; Evidence – appellate restraint on disturbing trial judge’s credibility findings; Causation and proof – need for concrete evidence of damage and medical causation.
6 August 2019
Whether reliance on employer tribunal records and minor procedural departures justified dismissal for dishonest conduct.
Employment law – unfair dismissal – judicial review of disciplinary decisions – court may consider employer’s disciplinary and appeals records – procedural irregularities do not vitiate dismissal where overall fairness and substratum of facts exist.
2 August 2019
Whether pension-transfer consent varied written employment terms and whether ambiguous redundancy clauses must be construed against the employer.
Employment law – variation of written employment terms – consent vs pension transfer; redundancy – interpretation of ambiguous clauses; incorporation of statutory redundancy provisions into written contracts; contra proferentem; salary inclusive of allowances for terminal benefits; entitlement to continued wages when employer able to pay.
2 August 2019
Failure to pursue statutory appeal routes and notice requirements under customs law deprived the High Court of jurisdiction.
Jurisdiction – failure to exhaust statutory remedies and appeal routes under Customs and Excise Act and Regulations – section 164 notice and three‑month limitation – Regulation 126 appeal to Minister – Tax Appeals Tribunal jurisdiction under s.5 of Tax Appeals Tribunal Act.
2 August 2019
Whether the Intestate Succession Act applies to customary land and whether abandonment permits reallocation of such land.
Customary land – Intestate Succession Act inapplicability to customary land – Abandonment and reallocation of customary land – Standard and sufficiency of judicial reasoning – Appellate review of factual findings and credibility assessments.
1 August 2019
Court held acting for over six months did not automatically confer confirmation; termination by pay in lieu of notice was lawful.
Employment law — interpretation of acting provisions — clause 5.13.2(a) not deeming confirmation after six months; grievance-procedure breach not actionable if not pleaded; lawful termination by payment in lieu of notice; no constructive/unfair dismissal without proof; entitlement to terminal benefits depends on employment status and precedent.
1 August 2019
July 2019
31 July 2019
Appeal dismissed: dismissal upheld as procedurally adequate and not shown to have caused prejudice to the appellant.
Employment law – unfair dismissal – disciplinary procedure – staff manual compliance – composition of disciplinary committee – apparent bias – right to cross-examine – sufficiency of evidence – hearsay and appellate review.
30 July 2019
Insufficient analyst and medical evidence and mis-evaluation of production safeguards defeated causation in a product-liability claim.
Product liability; duty of care by manufacturer; causation; insufficiency of public analyst and medical reports; proper evaluation of unchallenged production and sanitation evidence.
24 July 2019
Claim failed because analyst and medical evidence did not establish causation between the drink and the respondent's fungal infection.
Product liability/negligence – causation – adequacy of public analyst and medical reports – evidential requirements to link alleged contaminated beverage to injury – evaluation of manufacturer’s sanitization and inspection evidence.
24 July 2019
Whether a restructuring 'special dividend' was capital or revenue in nature and whether withholding tax relief under section 91 was available.
Income Tax — Withholding tax on dividends; characterization of distributions as capital or revenue; test considers application (use) of distributed profits not solely source; section 2(3) Income Tax Act; relief under section 91; Companies Act — share premium account uses.
23 July 2019
Whether a dividend arising from restructuring is capital or revenue for withholding tax purposes.
Tax law – withholding tax on dividends; dividend characterisation – capital v. revenue; test depends on application not solely source; restructuring transactions; s.2(3) Income Tax Act; relief under s.91.
23 July 2019
Appellant failed to prove ownership; customary alienation by chief after local consultation was valid.
Customary land — Alienation by chief with headman and village committee — validity where local customary procedures followed; Civil standard of proof — balance of probabilities in competing oral evidence; Evaluation of witnesses — failure to call material witness may undermine claim; Distinction between alienation of State land and customary land (Lands Act provisions inapplicable).
23 July 2019
Damages for unfair dismissal reduced to 12 months due to fixed-term contract and mitigation by respondent.
Employment law - unfair dismissal; damages for wrongful termination; fixed-term contract and mitigation; unjust enrichment; quantum of damages; interest at Bank of Zambia average deposit/lending rates; forensic exoneration.
23 July 2019
Transitional constitutional provisions can preserve appellate rights pending enactment of enabling legislation; motion dismissed, no costs.
Constitutional transition — continuity of laws pending enactment of enabling legislation — jurisdiction to grant leave to appeal; accrued rights preserved by transitional provisions; validity and scope of Practice Directions during constitutional transition; role of Constitutional Court vs other superior courts in constitutional interpretation.
16 July 2019
Whether a permanent resident qualifies to purchase a government institutional house without presidential written consent under s3(3).
Lands Act s3(3) – statutory construction: subsections disjunctive; permanent resident (s3(3)(a)) independently qualifies non‑Zambians to own land; Civil Service Home Ownership Scheme eligibility; presidential written consent (s3(3)(c) required and non‑delegable); evidentiary requirement for presidential consent; sale of government institutional houses.
9 July 2019
Whether section 3(3) of the Lands Act is disjunctive and whether ‘permanent resident’ status alone suffices to acquire land.
Lands Act s.3(3) – statutory construction; subsections disjunctive; permanent resident (s.3(3)(a)) suffices to own land; presidential consent (s.3(3)(c)) requires writing under President’s hand; eligibility for government institutional house under Civil Service Home Ownership Scheme.
9 July 2019
Court held respondent was an employee (contract of service) despite lump-sum payments and lack of statutory deductions.
Employment law — contract of service v contract for services — definition of 'employee' under Employment Act — method of remuneration not determinative — evidentiary weight of employer-originated documents — statutory deductions not conclusive.
9 July 2019
Appellant's conviction upheld where officer's eyewitness chase and capture placed him fleeing the scene despite ballistic inconsistencies.
Criminal law – Conviction on evidence of flight and pursuit – Eyewitness police chase as direct evidence; admissibility of evidence obtained without warn-and-caution; no obligation to call s.294 evidence where credibility resolved; ballistic mismatch not fatal where presence at scene proved.
9 July 2019
Circumstantial evidence including recent possession, blood-stained clothes and flight upheld convictions; identification found reliable.
Criminal law – aggravated robbery and murder – circumstantial evidence – recent possession and flight – identification evidence – risk of mistaken identity – failure to call informants.
5 July 2019
June 2019
Application for leave to appeal from an arbitral award dismissed for lacking public importance and reasonable prospects of success.
Civil procedure – Leave to appeal – Section 13(1) and (3) Court of Appeal Act – Appeal to Supreme Court requires point of law of public importance and reasonable prospects of success; Arbitration – challenge to arbitral award – substantive impeachment of award not ordinarily public law; Public policy – denial of relief in arbitral award does not automatically engage public importance.
26 June 2019
A mortgagee’s lawful sale extinguishes the mortgagor’s equity of redemption; the respondent’s purchase defeats the appellants’ specific performance claim.
Contract law — good faith and fair dealing cannot override express contractual or post-agreement arrangements; Mortgage law — mortgagee in possession’s right to sell under court consent order; Equity of redemption — extinguished upon lawful sale by mortgagee in possession; Specific performance — unavailable where entire property sold to third party purchaser; Recovery of deposit — failure of consideration and unjust enrichment.
11 June 2019
Appellant failed to prove respondent sold goods beyond those listed; respondent entitled to repossess under retention-of-title; appeal dismissed.
Contract law – Sale and Purchase Agreement with retention-of-title (Romalpa) clause; distraint and execution; onus of proof in allegations of wrongful sale/removal of goods; appellate review of factual findings.
11 June 2019
Appeal dismissed where grounds failed to challenge dismissal and extension issues could not affect the outcome.
Civil procedure — extension of time — restoration to active cause list — dismissal for want of prosecution — appellate jurisdiction — appeal must challenge operative dismissal order.
11 June 2019
Order 113 summary ejectment appropriate where documentary evidence shows no real or serious dispute of title.
Civil procedure – Order 113 summary possession proceedings; when summary procedure inappropriate – court may examine affidavits and documents to determine if dispute is real; conversion under Order 28 discretionary; proof required to establish claim of right.
11 June 2019
Court finds no provocation or extenuating circumstances; murder conviction and death sentence affirmed.
Criminal law – Provocation – Elements: act of provocation; actual and reasonable loss of self‑control; proportionate retaliation – Insults by a child not sufficient provocation – Extenuating circumstances not made out – Murder conviction and mandatory death sentence upheld.
10 June 2019
Whether acting six months creates automatic confirmation and whether contract termination by payment in lieu was wrongful.
Employment law – acting appointments – clause 5.13.2(a) does not automatically deem confirmation; Employment law – termination – payment in lieu under contract lawful absent proven malice; Industrial relations – applicability of precedent limited by differing employment status; Damages – mental anguish claims require pleading and evidential proof.
10 June 2019
Appellate court reduced an excessive 25-year manslaughter sentence to five years, giving weight to the appellant’s guilty plea and first-offender status.
Criminal law – Manslaughter – Sentencing – Manifestly excessive sentence – Trial judge’s misdirection by relying on facts not in agreed statement – Mitigation: guilty plea, first offender and remorse – Appellate interference and reduction of sentence.
10 June 2019
The appeal alleging a defective s169(1) CPC judgment failed; convictions upheld and aggravated robbery sentence increased.
Criminal procedure – sufficiency of judgment under s169(1) CPC – appellate discretion to decide on record; Evidence – eyewitness identification; confession statements; possession of recently stolen property presumption; Sentence – variation of inadequate mandatory minimum for aggravated robbery.
10 June 2019
Whether statutory retirement benefits vested as accrued rights and whether employment contract incorporated statutory minimum terms.
Contract interpretation – clause deeming original contract to apply to continued employment; statutory incorporation – whether a general choice‑of‑law clause imports specific statutory minimums; accrued statutory rights – section 14(3)(c) preserves only specific rights whose conditions were satisfied pre‑repeal; proof of entitlement to housing allowance.
7 June 2019
Transfer reversed where director acted personally; Turquand rule cannot be used to bind the Minister—appeal dismissed.
Mining law — transfer of mining licence (Mines and Minerals Development Act s61) — Company law — director’s authority and limits (Companies Act s216(1)(a)) — Indoor management/Turquand rule not enforceable against administrative decision-maker — Natural justice/consultation (s150) and subsequent right of appeal.
7 June 2019
A broadcaster cannot rely on justification or public interest where it conceals medical evidence and denies the subject a right to reply.
Defamation — alleged defilement broadcast; justification (truth) — failure where medical report known but omitted; right to be heard — failure to obtain comment; public interest/qualified privilege — Reynolds factors and responsible journalism; repeated broadcasts and malice/recklessness.
7 June 2019
A broadcaster’s failure to verify, seek comment, and disclose medical findings defeated its justification and public-interest defences.
Defamation – defamatory meaning – justification (truth) – public interest/reynolds qualified privilege – responsible journalism – failure to verify/seek comment – omission of medical evidence – opportunity to be heard.
7 June 2019
Defective trial judgment; evidence did not prove murder beyond reasonable doubt; conviction reduced to common assault.
Criminal law – Murder – Defective written judgment (s.169 Criminal Procedure Code) – Supreme Court’s section 15 jurisdiction to determine merits – Causation and reasonable doubt where multiple assaults occurred – Identification evidence – Res gestae inadmissible.
5 June 2019