Supreme Court of Zambia - 2024

33 judgments

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33 judgments
Citation
Judgment date
November 2024
Whether a High Court may extend time for an appeal previously dismissed by the Court of Appeal.
Civil procedure – jurisdiction – extension of time to appeal – effect of a Court of Appeal single-judge dismissal – resuscitation of a dismissed appeal – permission to appeal – public importance – mootness.
8 November 2024
October 2024
Whether the Director of Mining Cadastre may grant mining access over surface rights without notice, and jurisdictional consequences.
23 October 2024
Turquand rule inapplicable where respondent had actual knowledge of evident internal irregularities in the vendor company.
Company law – Turquand/Indoor Management Rule – exceptions where suspicious circumstances or notice exist – purchaser’s duty to make minimum enquiries – Members' resolution required for disposal of company assets – title cancellation for fraud/irregularity.
7 October 2024
Renewed application for permission to appeal refused: applicant failed to meet statutory threshold of public importance, prospects, or compelling reasons.
Appellate procedure – Permission to appeal to Supreme Court – Section 13(3) Court of Appeal Act – tests: point of law of public importance; reasonable prospects of success; other compelling reasons – BIDVEST principles applied. Civil procedure – renewed applications – confined to grounds raised below. Affidavit practice – interlocutory proceedings permit statements of information or belief with source; evidence must be properly served; skeleton arguments cannot substitute affidavit evidence. Res judicata – settled law, not raising public importance.
4 October 2024
August 2024
Whether the Supreme Court may entertain applications for leave to appeal despite Article 131(2) vesting leave in the Court of Appeal.
Constitutional law — Jurisdiction of superior courts — Whether Supreme Court may entertain applications for leave to appeal — Interaction of Articles 125 and 131 — Role of other written laws (Supreme Court Act, Rules) in conferring jurisdiction.
15 August 2024
Failure to serve a required demand letter on every defendant renders a writ incompetent and cannot be cured by registry acceptance.
Civil procedure — Order VI High Court (Amendment) Rules 2020 — Requirement to serve letter of demand on each defendant before issuing writ — Writ unsupported by prescribed documents not to be accepted — Registry acceptance does not cure jurisdictional defect — Imputed notice to related companies insufficient.
15 August 2024
Appellant's failure to plead and prove public-policy grounds under Rule 23 rendered its challenge to the arbitral award incompetent.
Arbitration — setting aside award under s.17 — public policy; Arbitration (Court Proceedings) Rules r.23(2)(c) — affidavit must state facts relied upon; Limited judicial review — courts may examine due process and jurisdiction, not merits; Pleading and proof obligations — grounds not raised in High Court cannot be first advanced on appeal.
7 August 2024
July 2024
An equitable contractual lien and a restored possession order entitled the respondents to be joined to the mortgage action.
Equitable (contractual) lien under construction contract – sufficiency for joinder to mortgage action; mechanic’s (statutory) lien not applicable in Zambia; prior restored judgment granting possession reinforces interest; joinder appropriate where decision affects non-party’s interest; registration under Lands and Deeds Registry Act not necessarily fatal to equitable lien.
24 July 2024
Applicant's renewed leave to appeal denied; no novel point of law and factual findings on title and fraud upheld.
Civil procedure – leave to appeal – Section 13 Court of Appeal Act – question of law of public importance; Order 28 RSC (White Book) – originating summons deemed writ – directions; Pleading of fraud – particularity v. reliance on unopposed evidence; Property law – bona fide purchaser for value and due diligence; Appellate restraint on findings of fact; Costs – award to non-attending party.
24 July 2024
Supreme Court holds Court of Appeal lacked jurisdiction over substantive Article 28 appeal and vacates its judgment.
Constitutional law – Article 28 appeals – appellate route and jurisdiction – interlocutory versus substantive appeals – Court of Appeal lacked jurisdiction – decision void and vacated; procedural commencement (petition vs writ) noted.
23 July 2024
The Court of Appeal lacked jurisdiction to hear a substantive Article 28 appeal; its judgment was vacated.
Constitutional law — Article 28 appeals — jurisdictional route for appeals from High Court on Bill of Rights — Kabwe Order; Hakainde Hichilema clarification — decision without jurisdiction void — mode of commencement of constitutional claims.
23 July 2024
June 2024
Whether a one-year delay for power connection was reasonable under the contract and Regulation 14.
[Contract law] Reasonable time for performance; interpretation of 'at the earliest possible time' and Regulation 14; notice making time of the essence; judicial notice of a party's status as sole national supplier; assessment of procurement and COVID-19 delays.
19 June 2024
Conviction upheld where voluntary confession and recent possession proved guilt; second appellant's appeal abated on death.
Criminal law – Confession admissibility – Burden to prove voluntariness – Trial-within-a-trial credibility assessment – Recent possession doctrine – Appeal abatement on death of appellant.
11 June 2024
Admissions to village headmen or neighbourhood watchmen are admissible absent coercion; voluntariness is a credibility issue.
Criminal law – admissibility of confessions – Judges' Rules apply to persons in authority only – admissions to village headmen/neighbourhood watchmen admissible absent coercion – voluntariness and credibility – afterthoughts – failure to produce postmortem not fatal where evidence cogent.
11 June 2024
Conviction unsafe where prosecution failed to rule out accidental fire despite voice-identification and threats evidence.
Criminal law – murder by arson – circumstantial evidence – necessity to exclude accidental fire where no eyewitness; voice-identification and Turnbull guidance; relatives as potentially suspect witnesses – bias must be evidenced.
11 June 2024
Detention with an accused does not make a witness an accomplice; motive and corroboration determine testimonial reliability.
Criminal law – suspect witnesses – distinction between accomplice and witness with interest; motive to give false evidence required before special caution; detention with accused not determinative; corroboration and unchallenged evidence may render conviction safe.
10 June 2024
Last‑seen circumstantial evidence and witness credibility upheld as sufficient to sustain a murder conviction; appeal dismissed.
Criminal law — Circumstantial evidence — 'Last seen with' principle — Admissibility and weight of statements to private witnesses — Credibility assessments — Non‑investigation and dereliction of duty — Murder; malice aforethought.
10 June 2024
Whether provocation or false implication excused a fatal stabbing; court found no heat of passion and dismissed the appeal.
Criminal law – murder – provocation – elements: sudden grave provocation, loss of self-control, proportionate retaliation; witness credibility – interested witnesses and need for corroboration; fals e implication – danger where witnesses have interest; sentence – failed provocation does not constitute extenuating circumstances for mandatory death penalty.
6 June 2024
Provocation and self‑defence not established; corroboration of suspect witness upheld murder conviction and death sentence.
Criminal law – murder; provocation; self‑defence and defence of property; suspect witness caution and corroboration; mandatory death sentence; extenuating circumstances for sentencing.
6 June 2024
Appellant's self-defence and provocation defences rejected; murder conviction and 45-year sentence upheld.
Criminal law – murder – self-defence – provocation – proportionality of force – appellate deference to trial findings – sentencing discretion – appeal determined on judgment-only record.
6 June 2024
May 2024
Appeals dismissed: identification, recent possession and ballistic evidence sufficiently proved armed robberies.
Criminal law – identification evidence – single and multiple identifying witnesses – recent possession doctrine – recoveries and scene reconstruction – definition and proof of firearm under the Firearms Act – appellate interference with trial findings of fact.
21 May 2024
Whether denial or suspension of driving licences for deaf persons breaches constitutional rights to freedom of movement and non-discrimination.
Constitutional law — Road Traffic Act (ss.59,62,68) — Licensing and suspension of drivers with hearing impairment — Article 11 (protection of the law) — Article 22 (freedom of movement protects liberty to move, not means) — Article 23 (entrenched text did not expressly include disability) — Persons with Disabilities Act and UNCRPD as alternative remedies.
16 May 2024
Denial or suspension of driving licences for deaf persons did not, per se, violate Articles 11, 22 or 23 of the Constitution.
Constitutional law — Part III rights — protection of the law, freedom of movement and non-discrimination — scope of Articles 11, 22 and 23; Road Traffic Act — fitness to drive and public safety; Persons with Disabilities Act and UNCRPD — alternative remedies.
16 May 2024
The State successfully appealed: extenuation lacked evidential basis and the six-year sentence was quashed for mandatory death.
Criminal law – Murder – Extenuating circumstances must be evidence-based – Defence of property cannot be raised for first time at sentencing – Appellate power to quash and substitute sentence where substantial miscarriage of justice – Substitution of mandatory death despite sentence served.
16 May 2024
Conviction based solely on circumstantial coincidence and lack of identification was unsafe; appeal allowed and acquittal ordered.
Criminal law – circumstantial evidence – sufficiency of coincidence of injuries as incriminating link – identification parades – police dereliction of duty – reasonably possible defence creates reasonable doubt.
15 May 2024
Conviction overturned for reliance on uncorroborated interested witnesses and improperly admitted confession evidence.
Criminal law – murder; corroboration of interested witnesses; hearsay; caution over evidence of detained/suspect witness; admissibility of confessions — court must ask defence to object; ballistic evidence not conclusive.
14 May 2024
The Supreme Court held it may determine its own jurisdiction to grant leave to appeal and need not refer that question to the Constitutional Court.
Constitutional jurisdiction — Whether Supreme Court may grant leave to appeal to itself after Court of Appeal refusal — Article 131 interpretation — Article 128(2) referral to Constitutional Court — Mandona precedent.
8 May 2024
Termination by notice communicated via a group HR officer was valid; wrongful dismissal yields damages, not nullity, and entitlements lacked proof.
Employment law – validity of termination by notice communicated by parent-group official – master-and-servant relationship – wrongful termination is breach (damages) not nullity; delving behind termination requires evidence of improper motives; acting allowance and salary increase require clear proof or formal contract amendment.
6 May 2024
April 2024
Application for leave to appeal dismissed; filing was timely and counsel wrongly condemned, but proposed grounds failed statutory threshold.
Civil procedure — leave to appeal to Supreme Court — computation of time under Supreme Court Rules (public holidays) — mischaracterisation of ruling dates and counsel misconduct — section 13(3) Court of Appeal Act threshold for leave (point of law of public importance, prospects of success, compelling reasons) — appellate power under section 24 to grant relief necessary for justice — no novel unjust enrichment issue.
25 April 2024
Whether a Director may authorise use of government vehicle and driver for private consultancy and whether that constitutes abuse of office.
Abuse of authority of office – authorisation of government vehicle and driver for private consultancy – Director of Geological Survey powers under s124 Mines and Minerals Development Act – credibility of administrative witnesses – sentencing for misdemeanour; fine preferred for first offender.
19 April 2024
Whether the appellant proved a statutory honest-belief defence as to age, and whether the 40-year sentence was excessive.
Criminal law – Defilement – Statutory defence of honest belief as to age under s.138(1) – requirement of reasonable cause and actual belief – sentencing discretion for defilement (15 years to life) – appellate interference only if sentence shocks court.
19 April 2024
March 2024
Whether Bundabunda chieftaincy is rotational and whether the Kashimbi lineage is entitled to the next succession.
Customary law – chieftaincy succession – rotation among matrilineal lineages; probative weight of family trees and contemporaneous joint reports; admissibility and weight of oral/traditional evidence (shrine clay pots); appellate interference with trial findings of fact where documentary inconsistencies and absence of verification exist.
20 March 2024
Evidence of telephone confirmations and corroborating call-back stamps upheld a court-martial conviction despite a harmless misdirection about producing signature comparisons.
Criminal law – Courts-martial appeal – Defence Act s.138 – proof of handwriting/signature by witness confirmation and corroborative documentary evidence; burden of proof – misdirection harmless where independent evidence supports conviction; disclosure obligations – prosecution not required to produce comparative signatures when accused effectively admits or confirms authorship; procedural irregularity – failure to deliberate in private requires shown prejudice.
6 March 2024