Supreme Court of Zambia - 2022

47 judgments

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47 judgments
Citation
Judgment date
December 2022
29 December 2022
Appellants' corruption convictions and five-year sentences upheld; statutory presumption valid and foreign documents admissible.
Criminal law – Corruption – proof of overpayments and corrupt gratification; Admissibility – foreign documents and authentication; Constitutional law – right to silence vis-à-vis statutory presumptions in anti‑corruption legislation; Evidence – use of intelligence-related material and presidential consent; Corporate law – lifting the veil to attribute personal criminal liability to corporate officers; Sentencing – custodial deterrent sentences for corruption.
29 December 2022
November 2022
Renewed application for leave to appeal denied; alleged fraud and locus standi procedural failings do not justify setting aside arbitral award.
Arbitration — limited court intervention; Arbitration Act s17 — grounds to set aside awards (fraud, public policy, jurisdictional limits); Court of Appeal Act s13(3) — threshold for leave to appeal; procedural requirement to renew single-judge applications (renewal, not appeal); failure to produce evidence at arbitration not basis for setting aside award.
9 November 2022
Beneficiaries cannot prosecute claims over deceased estate property without a duly appointed administrator; Rule 19 objections are permitted.
Succession law – capacity to sue – administrators derive authority from letters of administration (Intestate Succession Act s.24(1)) – beneficiaries lack locus to prosecute estate claims – preliminary objections under Rule 19 of the Supreme Court Rules.
9 November 2022
October 2022
Chief’s alleged withdrawal or consent could not validly extinguish another’s customary interest without required consultation under the Lands Act.
Customary land – boundary demarcation by chief’s retainer – effect on competing grants; Lands Act s.3 – requirement to consult persons with affected interests; alienation of customary land void without consultation; prior interest protection under customary tenure.
31 October 2022
September 2022
A section 22(1) challenge to a business‑rescue resolution is not subject to the section 25(1) moratorium and does not require administrator consent.
Corporate insolvency law – business rescue – distinction between challenges to the decision to commence business rescue (section 22(1)) and the moratorium on proceedings affecting company assets (section 25(1)) – scope of "legal proceedings" – procedure for section 22(1) applications.
29 September 2022
A mortgagee may lodge a counterclaim in pending writ proceedings; mode of commencement does not bar competent counterclaims.
Civil procedure — Counterclaims — Whether mortgage actions must be commenced by originating summons — Order 30 r.14 High Court Rules — Order 28 r.3 and RSC Order 15 — Mode of commencement and jurisdiction — Multiplicity of actions.
1 September 2022
A mortgage action may be pursued as a counterclaim in writ proceedings; jurisdictional objections can be raised at any stage.
Civil procedure — counterclaim — mortgage/foreclosure matters — Order 30 r.14 not precluding counterclaims; counterclaim as extension of defence (Order 28 r.3; RSC Order 15 r.2) — jurisdictional objections may be raised at any time.
1 September 2022
August 2022
Court upheld murder convictions, substituted death with 20 years due to mitigating postpartum psychosis; constitutional petition on MP exclusion dismissed.
Criminal law — Insanity defence (s.12 Penal Code) — onus on accused — psychiatric evidence must be cogent and explained — postpartum psychosis may mitigate though not meet legal insanity. Constitutional law — Article 73(4) — status of MP whose election nullified but appeal pending — MPs retain seats pending appeal; Speaker’s exclusion ruling rendered overtaken
31 August 2022
Claim for unpaid BIT allowance failed largely for lack of documentary proof; only admitted amounts and certain awards survive.
Contract construction; BIT (broken and missing bottles) allowance – scope and monetary entitlement – authority of employee to vary contract – burden and standard of proof in liquidated money claims – requirement for documentary evidence – improper referral to assessment – costs allocation.
30 August 2022
Applicant failed to show public importance or prospects of success; prior judgments made the claim res judicata and leave was refused.
Civil procedure — leave to appeal to Supreme Court (section 13 Court of Appeal Act) — threshold for certification — res judicata — Court of Appeal’s powers under section 24 to rehear and determine appeals on record — originating summons appropriate where no substantial dispute of fact — chieftaincy succession and recognition vs final judicial determinations.
24 August 2022
An offshore indirect transfer conferring control of a Zambian mining licence attracts property transfer tax; Commissioner-General may value consideration.
Property Transfer Tax — Offshore/indirect transfer of holding-company shares — Interest in mining right — Statutory interpretation — Commissioner-General's valuation discretion (s5(3)) — Legitimate expectation and power to amend assessment.
17 August 2022
July 2022
Appellant entitled to separate long service gratuity and housing allowance; defendant cannot resurrect limitation after defending on merits.
Procedure — limitation defence; where defendant elects to defend on merits after Deputy Registrar dismisses limitation plea, it cannot later revive limitation as jurisdictional bar — Employment law — interpretation of conditions of service — clauses 8 (long service gratuity) and 9 (retirement benefits) are distinct — entitlement to three months' pay per year and housing allowance until benefits paid — calculation on basic salary excluding allowances; account for amounts already paid and currency rebasing.
6 July 2022
June 2022
Equitable assignment of an equity of redemption (s.62) can vest full title upon redemption; equitable claims are not time-barred under s.2(7).
Conveyancing – Equity of redemption – Assignment vs outright transfer – Applicability of Lands and Deeds Registry Act sections 61 and 62 – Registration requirements – Equity and limitation (Limitation Act s.2(7)) – Delay, laches and subrogation.
22 June 2022
Appeal dismissed: unchallenged extrajudicial confession and note confirmed motive and premeditation, warranting murder conviction and death sentence.
Criminal law – murder – sufficiency of proof as to cause of death – extrajudicial confession to private person – admissibility and weight – motive and corroboration – mens rea/malice aforethought – appellate review of trial judge’s evaluation of conflicting accounts.
14 June 2022
Belief in witchcraft may mitigate murder sentence but is negated by an unprompted admission of being hired to kill.
Criminal law – Murder – Sentence – Belief in witchcraft as possible extenuating circumstance; mitigation; effect of unsolicited admission of being hired to kill.
13 June 2022
Whether a brief voir dire showing a child knows lying is wrong suffices under s122 to receive evidence on oath.
Juveniles Act s122 – Child witness – Voir dire requirements – Court must be satisfied child has sufficient intelligence and understands duty to speak truth – No prescribed questionnaire – Ocular observation and brief probing may suffice – No need to show knowledge of sanctions for lying.
13 June 2022
Eyewitness identification corroborated by possession of stolen property sustained appellant's conviction for aggravated robbery and murder.
Criminal law – Identification evidence and recent possession – Mutual corroboration of eyewitness identification by possession of stolen property – Circumstantial evidence – Aggravated robbery and felony murder.
10 June 2022
Failure to obtain mandatory leave from the Court of Appeal deprived the Supreme Court of jurisdiction, so appeals dismissed.
Criminal procedure — Appeal to Supreme Court — Mandatory leave to appeal from Court of Appeal (Court of Appeal Act s.13; Supreme Court (Amendment) Act s.17) — Order XI(5) of Court of Appeal Rules cannot displace statutory leave requirement — leave substantive and jurisdictional — Rule 37 and constitutional provision not a cure.
7 June 2022
Appeal against murder conviction dismissed: malice proved, no extenuating circumstances, life sentence set aside and death penalty imposed.
Criminal law – Murder v manslaughter – malice aforethought (s204 Penal Code) – deadly weapon (broken bottle) – contemporaneous statements – res gestae – drunkenness not automatically extenuating – sentencing misdirection – substitution of death penalty.
7 June 2022
May 2022
Summary possession under Order 113 RSC cannot resolve disputed title; matter remitted for full trial under Order 28(8) RSC.
Land law – Order 113 RSC (summary possession) limited to dispossessing trespassers; contentious ownership disputes require full trial or conversion under Order 28(8) RSC; procedural irregularities generally cureable under Order 2 RSC but not where misuse subverts the purpose of a special procedure; certificate of title issues cannot be resolved by summary procedure.
26 May 2022
Whether failure to dispose within the IRD's statutory one-year period divests the court of jurisdiction over the entire proceedings or only the judgment.
Industrial Relations Division — statutory one-year disposal requirement — effect of non-compliance on jurisdiction (judgment-only versus entire proceedings) — remit to trial court — point of law of public importance — leave to appeal granted.
20 May 2022
Two independent eyewitness identifications upheld despite a flawed parade; dying co‑suspect statement inadmissible against the appellant.
Criminal law – identification evidence – reliability of eyewitness identification after delay; identification parade irregularity (accused with visible injuries) – effect on admissibility; extra‑judicial/dying co‑suspect statement – admissibility and warn and caution; multiple independent identifications strengthens prosecution case.
10 May 2022
Appeal concerned whether eyewitness identification and identification-parade fairness sufficiently established aggravated robbery convictions.
Criminal law – Identification evidence – Duty to rule out honest mistake; witnesses must demonstrate quality of observation (light, duration, features). Identification parades – Allegations of photographs/clothing investigated; parade irregularity requires proof of unfairness. Multiple independent eyewitness identifications strengthen reliability
10 May 2022
Whether malice, self‑defence, and intoxication were correctly assessed on the evidence in a murder conviction.
Criminal law – Murder – Malice aforethought established by scene evidence and post‑offence conduct; Self‑defence – reliance on rejected testimony; Intoxication – extenuation only if shown to impair reasoning.
10 May 2022
April 2022
Pursuit of administrative remedies does not excuse unreasonable delay; applicant failed to give sufficient reasons for seeking leave to appeal out of time.
Civil procedure – extension of time – Supreme Court Rules Order 12 rule 1; Defence Act s137 – leave to appeal from courts-martial/boards of inquiry – discretionary extension only for sufficient reasons; administrative remedies do not indefinitely suspend statutory appeal periods.
12 April 2022
Leave to appeal refused: proposed grounds were factual, not points of law of public importance; motion dismissed with costs.
Civil procedure — Leave to appeal under s13 Court of Appeal Act — Point of law of public importance — Constructive dismissal — Unilateral variation of job description — Duty to consider filed submissions — Findings of fact v points of law.
1 April 2022
March 2022
Contract workers failed to prove entitlement to unpaid/underpaid camping allowances or retrospective settling‑in allowance; appeal allowed.
Employment law – conditions of service – camping/subsistence allowances – burden of proof for nights away and claim forms; collective agreements and union-negotiated rates – proof of union membership and payment; settling-in allowance – non-retroactivity; assessment of damages – proper procedure for verification/assessment.
30 March 2022
A single Supreme Court judge does not have jurisdiction to stay proceedings pending before the full court.
Constitutional and statutory interpretation – single judge jurisdiction – interlocutory applications – power to stay proceedings – hierarchy between single judge and full court – stay of proceedings; public interest in orderly adjudication.
29 March 2022
SI No. 6 of 2017 is non‑retroactive; employed advocates admitted on the roll are entitled to costs; calculational errors in a bill are curable.
Costs — Taxation of bill of costs — Effect of repeal and retroactivity of statutory instruments (SI No. 6 of 2017) — Curable procedural irregularity — Entitlement of employed (in‑house) advocates to costs — Definition of 'practitioner' under Legal Practitioners Act.
28 March 2022
Court granted extension under Rule 12 SCR where applicant filed within 21 days after becoming aware of the ruling.
Civil procedure – extension of time – Rule 12(1) and 12(2) Supreme Court Rules – 21-day filing requirement – excusable delay due to late knowledge of ruling and death of advocate – application for leave to appeal out of time.
23 March 2022
Delay beyond Rule 12(2)'s 21‑day limit led to dismissal of extension application despite counsel's illness.
Civil procedure – extension of time – Rule 12(1) and (2) Supreme Court Rules – 21‑day filing requirement – promptness and sufficiency of reasons – consideration of merits – application for leave to appeal out of time.
22 March 2022
A registered partial arbitral award precludes re-litigation of issues it decided, depriving the court of jurisdiction over related appeal grounds.
Arbitration law – registration and effect of a partial final award – issue estoppel and functus officio – limited court intervention – arbitrability of disputes under shareholders' agreements versus winding-up proceedings – status of notice to be heard in liquidation – abuse of process/multiplicity of actions.
22 March 2022
A registered partial final arbitral award on jurisdiction/arbitrability bars re-litigation of those issues in court, collapsing the appeal.
Arbitration — registered partial final award — finality of arbitral determinations on jurisdiction and arbitrability — limited court intervention — effect on related winding-up proceedings — abuse of process/multiplicity.
22 March 2022
The respondents’ delayed and procedurally misconceived attempts to nullify and settle judgments were dismissed as an abuse of process.
Civil procedure — Settlement of judgments into orders — Rule 75 requires settlement by presiding judge or judge who sat on hearing — Successful party’s duty to prepare draft order promptly — Challenges to judgments on jurisdiction/unfair procedure must follow Rule 48(1) and 48(5) and be timeous — Abuse of process and delay.
15 March 2022
Appeal against bribery conviction dismissed; undercover evidence and trial process found lawful and magistrate’s findings upheld.
Criminal law — Corrupt practice by public officer — solicitation and receipt of bribe; Anti‑Corruption sting operations — admissibility of marked notes and arranged meetings; Appellate review — credibility findings and alleged procedural irregularities (right to counsel, admission of guilt).
2 March 2022
February 2022
A renewed interlocutory injunction cannot be brought to the Supreme Court while the Court of Appeal is seised without prior leave.
Procedure — Appellate jurisdiction — Supreme Court’s restricted role post-2016 — Effect of Court of Appeal Act s.13 — Interlocutory injunctions — Renewed applications not permitted in Supreme Court while appeal pending in Court of Appeal without leave — Single judge cannot sit as appellate court over Court of Appeal — Requirement to specify terms of injunction.
23 February 2022
Leave refused: issues were private/interlocutory and did not raise points of public importance; application dismissed with costs.
Leave to appeal – Section 13 Court of Appeal Act – limited to points of general public importance; appellate procedural non-compliance (Order X Rule 9) – interlocutory; appellate contradiction – capable of clarification; measure of damages in wrongful dismissal – notice-period principle; application dismissed with costs.
23 February 2022
Leave to appeal refused: alleged smuggling did not render the contract illegal and proposed appeal raised only factual issues.
Leave to appeal – Section 13 Court of Appeal Act – Illegality in contract – alleged smuggling of funds does not invalidate contract absent illegal purpose – appellate review limited to questions of law, not re‑appraisal of factual findings.
22 February 2022
A Rule 10 interested party may challenge a consent winding‑up judgment; directors retain residual powers and the flawed liquidation must be re-opened.
Companies law – winding up – Rule 10 notice confers interested-party locus to be heard; consent judgments and third‑party rights; residual powers of directors in liquidation; provisional liquidator appointment; judicial supervision and procedural fairness; liquidator’s fiduciary duties; joinder of liquidator.
17 February 2022
Sworn evidence of a child aged 14+ need not be corroborated by law; corroboration remains practice in sexual offences.
Juveniles Act s122 – sworn evidence by child witnesses; corroboration statutory only for under-14s; sexual offences – corroboration a rule of practice; odd coincidences as corroboration; circumstantial evidence; identification.
10 February 2022
Counsel’s holiday and procedural error did not constitute good cause to extend time to reopen the appeal.
Civil procedure – Extension of time – Rule 12(1) Supreme Court Rules – Requirement of good cause and sufficient material – Counsel’s omission or mistake does not ordinarily justify extension – Reopening appeal – Promptness and explanation for delay.
8 February 2022
Whether circumstantial evidence and adverse credibility findings can safely sustain a murder conviction.
Criminal law – Circumstantial evidence – staged approach to infer facts – sufficiency to exclude hypotheses of innocence; Credibility – effect of inconsistencies and lies; Safety of conviction; Last-seen evidence; Forensic and CCTV evidence.
1 February 2022
January 2022
Court refused a late amendment to a motion (styled as an appeal) because allowing it would prejudice the appellant who had proceeded with the appeal.
Civil procedure – amendment of motions – motion styled as appeal – compliance with Supreme Court Rules (rules 48(1), 48(4)) – discretion to allow amendments vs prejudice and delay – effect of preparing record of appeal and absence of stay.
18 January 2022
Interim injunction granted where registered trade mark embossed on widely circulated bottles risked irreparable, unquantifiable harm.
Trade mark — Interim injunction — Adequacy of damages vs. irreparable harm — Balance of convenience — Owner’s rights in embossed packaging — Preservation and surrender of chattels bearing registered trade mark.
13 January 2022
Respondents granted 14-day extension where lack of notice excused delay; full-bench leave-to-appeal avenue must be exhausted.
Civil procedure — Extension of time to apply to full bench — s.4 Supreme Court Act & Rule 48 — Late receipt of reserved ruling — Jurisdictional nature of leave to appeal — Prejudice and cause-list management.
8 January 2022
A delivered judgment is enforceable immediately; embodiment under Rule 75 is not a prerequisite to taxing costs.
Civil procedure — enforcement of judgments — effect of delivery date — Rule 75 (embodiment of judgments) does not prevent enforcement — Section 9 Supreme Court Act governs execution — taxation of costs under Rule 77.
3 January 2022