Supreme Court of Zambia - 2019

184 judgments

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184 judgments
Citation
Judgment date
June 2019
A guilty plea must admit sufficient facts; a bare admission of the offence label is insufficient and warrants acquittal.
Criminal law – Plea of guilty – Requirement to admit sufficient facts under section 204 CPC – Plea must disclose elements of indecent assault – Inadequate plea and statement of facts render conviction unsupported.
5 June 2019
Trial court erred rejecting a reasonable explanation for possession of recently stolen property; conviction and sentence set aside.
Criminal law — Recent possession of stolen property — Duty to give reasonable explanation — Court's assessment of demeanour — Identification evidence — Alternative conviction for receiving stolen property.
5 June 2019
4 June 2019
4 June 2019
Wrongful dismissals upheld; reinstatement/re-engagement denied; two months' pay in lieu of notice awarded; no costs ordered.
Labour law — Collective bargaining and strike procedure — Whether a staff gathering amounted to a strike; burden of proof on employer to show who withdrew labour; remedies for wrongful dismissal — reinstatement exceptional; re-engagement procedural/practical limits; damages measured by reasonable notice period; costs discretionary.
4 June 2019
Across‑the‑board dismissals for alleged strike were wrongful; two months' pay awarded, reinstatement and re‑engagement not ordered.
Labour law — strike definition and ballot legality — burden to prove participation in strike lies with employer alleging misconduct — reinstatement rare, re‑engagement discretionary and practicability‑dependent — damages for wrongful dismissal usually measured by notice period — costs discretionary.
4 June 2019
4 June 2019
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
April 2019
Dismissal upheld where employee refused to attend disciplinary hearings and procedural flaws were not sufficiently gross to invalidate dismissal.
Employment law – wrongful dismissal – disciplinary procedure – right to be heard – employee refusal to attend disciplinary hearing – ACAS guidance – procedural irregularities not automatically fatal – appeal routes and apparent bias.
18 April 2019
A court cannot compel the respondent to sell institutional government houses to sitting tenants when those houses are not for sale.
Civil service home ownership; Institutional houses; Circular No.12 of 1996 clause 1.2; Ancillary use to institution; No court power to compel sale; Discrimination allegation; Factual findings not perverse.
18 April 2019
Whether a defective schedule invalidated excise on airtime, and whether wrongful excise on data should be refunded or escheat to the State.
Tax law — Customs & Excise — Validity and effect of schedules lacking express inducing sections — Excise on telecommunications services — valuation of airtime — consumption tax borne by consumers — distributor discounts as distribution costs — treatment of erroneously collected tax (escheat).
10 April 2019
10 April 2019
Whether unlawful development by an occupier defeats an interlocutory injunction protecting occupation rights.
Interlocutory injunction — requirement of clear right, irreparable injury and balance of convenience — applicant's conduct (clean hands) — unlawful development under planning law — Urban and Regional Planning Act s.71 — injunction conditioned on compliance with development laws — competing lease and memorandum of understanding.
1 April 2019
March 2019
28 March 2019
Whether employer had reasonable grounds and acted reasonably in dismissing employee for alleged forgery; court must not substitute its view.
Employment law – wrongful dismissal – scope of review by Industrial Relations Court – employer investigations and reasonableness test – fraudulent conduct justifying summary dismissal – appellate competence on mixed law and fact.
28 March 2019
Whether a financier was liable under a letter of credit: court held it was neither issuing nor advising bank and could enforce loan security.
Banking law – Letters of credit – UCP 600 – Separation of credit and sale contract (Article 4) – Duty to examine documents on issuing bank (Article 14) – Distinction between issuing, advising and confirming/nominated banks – Mortgage enforcement following borrower default.
28 March 2019
Arbitration cannot be imposed by the court suo motu; service, authentication and party-defects were curable—amendments and leave to serve permitted.
Civil procedure — service outside jurisdiction: leave required but non-compliance curable; authentication of foreign document — unauthenticated instrument valid between parties and signatory estopped from objecting; locus standi — amend/ substitute parties or plead cession; arbitration — court cannot refer to arbitration suo motu; stay must be sought under Arbitration Act s10 and Rules.
26 March 2019
Whether the appellant was validly dismissed for authorising suspicious cash refunds and entitled to accrued benefits and vehicle purchase.
Employment law – wrongful dismissal – disciplinary procedure and natural justice – dishonest conduct and negligence causing loss – forced leave by third party – accrued benefits and personal-to-holder vehicle eligibility.
22 March 2019
The respondent bank failed to ensure the appellants consented to continuing liability, so later facilities could not be secured by their mortgages.
Third-party mortgages – continuing security – bank’s duty to inform guarantor/surety – obligation to ensure independent legal advice – undue influence/relationship of trust – discharge of guarantee and consequent discharge of securities.
20 March 2019
Limitation periods bar joinder to pursue piercing of the corporate veil; amendments allowed if arising from same facts; witnesses not injuncted.
Limitation Act — joinder after expiry barred; Amendment of pleadings — Order 20(5)(5) allowed where new claim arises from same facts; Piercing corporate veil — s.383 applies in any proceedings but does not waive limitation; No property in a witness — injunctive restraint on testimony not warranted; Documents supplied at discovery — late objections may be barred.
20 March 2019
Statutory limitation bars post‑limitation joinder and veil‑piercing; pleadings may be amended if arising from same facts.
Limitation of actions — Joinder after limitation period — Amendment of pleadings (Order 20(5)) — Piercing corporate veil — Companies Act s.383 — Jurisdictional nature of limitation — Witness confidentiality and expunging evidence.
20 March 2019
An arbitrator's non-disclosure of a relationship with the respondent can render an award contrary to public policy and void.
Arbitration — Duty of disclosure — Arbitrator's continuing obligation to disclose relationships (Regulation 2 SI No.12 of 2007) — Non-disclosure creates perception of bias — Award may be set aside under Section 17 of the Arbitration Act and Article 34 of the Model Law as contrary to public policy — Article 12 challenge does not bar later annulment.
20 March 2019
Arbitrator’s non‑disclosure of a personal relationship can create perceived bias and justify setting aside the award on public policy grounds.
Arbitration — Duty of disclosure — Arbitrator must disclose prior interests/relationships — Non‑disclosure creates perception of bias — Public policy (Section 17 Arbitration Act & Article 34 Model Law) — Article 12 challenge to appointment does not bar later setting aside — Courts’ limited review of merits.
20 March 2019
Non‑disclosure by an arbitrator of a personal relationship can create perceived bias and justify setting aside an award as contrary to public policy.
Arbitration law – Duty of disclosure – Arbitrator’s personal/family relationship – Perception of bias – Public policy ground under Section 17/Article 34 – Article 12 challenge and waiver – Judicial review limited but permits intervention for non‑disclosure.
20 March 2019
An employer’s creation of a Minister‑approved pension scheme displaces prior accrued benefit formula; employee consent is not required.
Employment law – Pension schemes – Interpretation of clause importing paragraph 8 of SI No.119/1997 – Effect of employer’s establishment of Minister‑approved pension scheme on accrued retirement benefits – Consent and acquiescence – Transfer of liability via contributions/letter of 4 August 2011.
19 March 2019
Unfounded public allegations of judicial corruption amount to contempt; apology mitigates but a punitive fine was imposed.
Contempt of court — scandalizing the court by imputing corruption to judges — limits of permissible criticism — mitigation by apology and guilty plea — sentencing: fine or imprisonment.
15 March 2019
Unsubstantiated rumours, withdrawn and apologised for by their author, cannot support a contempt citation against the mentioned person.
Contempt of court — scandalizing the court by imputing judicial bias — allegation based on rumour — third‑party author’s apology and withdrawal — insufficiency to sustain contempt citation.
15 March 2019
An unsubstantiated, withdrawn allegation cannot sustain a contempt citation against an alleged contemnor.
Contempt of court – scandalizing the court – imputation of bias against a judge – necessity of substantiation for contempt citations – effect of withdrawal and unreserved apology by author on contempt proceedings against a third party.
15 March 2019
Written, unsubstantiated accusations of judicial corruption constitute contempt and attract a deterrent fine or imprisonment.
Contempt of Court – written allegations of judicial corruption – plea of guilty and apology – mitigation and sentencing – deterrent sentence to protect judicial independence and public confidence.
15 March 2019
Court held the later claims were not res judicata, were not time‑barred under section 19(1)(b), and deceased plaintiffs may be substituted for trial.
Civil procedure — res judicata — conditions for plea of res judicata; Limitation — section 19(1)(b) Limitation Act 1939 and constructive trust; Substitution — deceased plaintiffs and personal representatives; Abuse of process and procedural technicalities vs. trial on merits.
13 March 2019
An out-of-time appeal without leave is incompetent; a judge's s305(1) recommendation after the appeal period places the matter within the Executive and bars a later appeal.
Criminal procedure – appeal filed out of time without leave – Rule 12 Supreme Court Rules – section 305(1) Criminal Procedure Code – recommendation to President/prerogative of mercy bars subsequent appeal after appeal period.
13 March 2019
A deficient trial judgment does not mandate acquittal where the record establishes aggravated robbery beyond reasonable doubt.
Criminal law – Aggravated robbery – Proof of violence in obtaining property – Trial judgment requirements under s.169 Criminal Procedure Code – Defective judgment does not automatically require acquittal where evidence proves offence – Sentencing: requirement to give reasons; limits on appellate enhancement absent proper charge.
13 March 2019
Ballistics reports may be admissible via the arresting officer; eyewitness and circumstantial evidence can sustain armed robbery convictions.
Evidence – Ballistics report admissibility; arresting officer may tender report where no objection. Criminal law – proof of firearm use; eyewitness and circumstantial evidence may establish armed robbery Identification – visual ID and recovery of stolen property link accused to offence
13 March 2019
13 March 2019
13 March 2019
A deficient trial judgment did not vitiate conviction where evidence proved aggravated robbery, but sentencing required stated reasons.
Criminal law – Aggravated robbery – Sufficiency of evidence; Criminal procedure – Judgment writing – Section 169(1) compliance; Sentencing – requirement to give reasons and prosecution’s role (Section 302); Trial management – related offences should be tried together to avoid multiplicity (Article 18).
13 March 2019
Leave to seek judicial review was refused because the challenge to a 2005 decision was inordinately delayed and would harm public administration.
Administrative law — Judicial review — Leave to apply — Limitation — Order 53 rule 4 — One‑off decision v continuing decision — Implementation does not restart limitation — Inordinate delay — Public interest and protection of good administration — Sufficient interest and prima facie case insufficient where delay fatal.
11 March 2019
Commencing fresh proceedings instead of setting aside an unchallenged earlier judgment constituted duplicity and abuse of process.
Civil procedure — Duplicity of actions; abuse of process; Rules of the Supreme Court O.113; setting aside judgment for lack of service; risk of conflicting enforceable judgments.
11 March 2019