Supreme Court of Zambia

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3,930 judgments
Citation
Judgment date
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
December 2021
A single judge cannot extend time to reopen a full court judgment; alleged slips were substantive, not clerical.
Procedure — Jurisdiction of single judge to extend time — Finality of full court decisions — Slip rule: clerical error vs substantive attack — Time runs from perfected judgment (signed/sealed/dated).
30 December 2021
Court dismissed leave to appeal as moot and declined to decide whether Order 3 or local statutes govern time computation.
Judicial review — computation of time — applicability of Order 3 (White Book) versus local statutes — mootness doctrine — leave to appeal under section 13 of the Court of Appeal Act.
29 December 2021
Out‑of‑time leave and stay dismissed; exhibited ruling found altered and counsel referred for possible professional misconduct.
Civil procedure — leave to appeal — mandatory 14‑day time limit under Supreme Court Rules (rule 48(1)) — extension under rule 12 — stay of execution — appellate jurisdiction to vary judgments — falsified court document — counsel’s professional misconduct referral.
24 December 2021
A litigant’s counsel’s mistaken belief about appeal deadlines does not justify extending time for leave to appeal.
Civil procedure — Extension of time under Rule 12; leave to appeal to Supreme Court; counsel's mistaken belief about time limits; procedural default; merits requirement for leave; costs.
23 December 2021
A recast renewed application is permissible, but private mortgage-accounting issues lacked public importance; leave refused with costs.
Civil procedure — renewed application for leave to appeal — competence of a recast application before a single judge — leave criteria under section 13: public importance, prospects of success, other compelling reasons — mortgagee in possession and receivership accounting — burden of proof.
17 December 2021
Leave to appeal from a court-martial refused because the applicant failed to file proposed grounds and the trial transcript.
Defence Act — appeals from courts-martial — leave to appeal required — applicant must provide proposed grounds and court-martial transcript to show prospects — procedural compliance (Order 59 r.4).
17 December 2021
Second‑hand trailers qualify for SADC preferences only if imported solely for recovery of raw materials.
SADC Protocol – rules of origin – interpretation of Rules 2(1) and 4(1) – used/second‑hand goods; certificates of origin prima facie but verifiable (Rule 9(3)); legitimate expectation not founded on unlawful/mistaken representation; tax exemptions interpreted strictly.
15 December 2021
Related eyewitnesses' evidence need not be treated as suspect absent bias; photographic and post‑mortem corroboration can sustain conviction despite fingerprint omissions.
Criminal law – eyewitness evidence – related witnesses not automatically suspect; corroboration by photographs and post‑mortem – identity corroborated by presence at scene – failure to fingerprint weapon not fatal where ample other evidence implicates accused.
7 December 2021
Whether a withdrawn cross-appeal may be restored years later when no fundamental error is shown and counsel misled the court.
Practice and procedure — Appeal and cross-appeal — Restoration of withdrawn cross-appeal — Rule 48(5) and Rule 63 — Fundamental error as basis for restoration — Withdrawal vs nullity — Abuse of process — Duty of legal practitioners not to mislead court — Personal costs for misconduct.
2 December 2021
November 2021
Cogent circumstantial evidence and credible weapon identification upheld conviction; appeal dismissed.
Criminal law – Circumstantial evidence – Identification of weapon – Alibi – Appellate review of witness credibility and findings of fact.
2 November 2021
October 2021
Appellant may withdraw and amend a defective record of appeal under Rule 68 where respondents suffer no prejudice.
Civil procedure – Appeal – Record of appeal – Compliance with Rule 58(2) & 58(4)(j) – Amendment under Rule 68 – Supplementary record under Rule 59 – Dismissal vs curative amendment – Prejudice test.
27 October 2021
26 October 2021
Appeal dismissed: conviction for indecent assault upheld based on opportunity, unexplained conduct and guard's evidence despite limited direct corroboration.
Criminal law — Sexual offences — Requirement of corroboration of both commission and identity — Corroboration by opportunity and unexplained 'odd coincidences' — Late complaint by a child complainant — Appellate review of sufficiency of evidence.
5 October 2021
September 2021
24 September 2021
Renewal motion was incompetent because it functioned as an appeal, not reasserting original grounds to meet section 13 threshold.
Procedure — Renewal to full Court under section 4(b) Supreme Court Act and rule 48(4) — Distinction between renewal and appeal — Competency of motion where applicant attacks single judge rather than reasserting original grounds to meet section 13(3) threshold (Court of Appeal Act).
22 September 2021