Corruption, Fraud and Illicit Money Flows

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Corruption, Fraud and Illicit Money Flows

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88 documents
Out-of-time leave refused where procedural sequence under Order 13 was not followed and delay was inadequately explained.
  • Civil Procedure
    • — Appeals — Extension of time for filing application for leave to appeal out of time — Requirement to obtain leave where both 14-day and further 21-day periods have expired — Order 13 Rule 3(2) and (3)
    • — Rules of Court — Procedural compliance — Application incompetent where prescribed procedural sequence is not followed
Judgment 11 June 2026
The accused person used public office to secure his sister's appointment—convicted of abuse, forgery and uttering; acquitted on one count.
  • Anti‑corruption law — Abuse of authority — Use of public office to obtain advantage for a relative — Anti‑Corruption Act s21(1)(b) and s21(2)
  • Criminal law
    • — Forgery — Making a false document with intent to deceive — Penal Code s342/s347
    • — Uttering false documents — Use, dealing with and inducing action upon false documents — Penal Code s4/s352
Judgment 28 May 2026
Plaintiff succeeds in malicious prosecution claim; defamation claim fails for lack of proof of defamatory effect.
  • Civil
    • — Malicious prosecution — Elements and proof — Termination in claimant's favour; absence of reasonable and probable cause; malice
    • — Defamation (libel) — Publication and defamatory effect — Requirement to adduce evidence of impact on right‑thinking members of society
Judgment 18 May 2026
Prosecution failed to prove the accused wilfully breached approval procedure for fuel imprests due to lack of procedural documentation.
  • Criminal law — Anti‑corruption — Wilful failure to follow laid down procedure — Proof of ingredients and onus of prosecution — Anti‑Corruption Act No.3 of 2012 s 34(2)(b), s 41
  • Public finance — Administrative procedure — Fuel imprest formula versus approval procedure — Cabinet Office Circular No.7 of 2012
  • Evidence — Documentary proof required to establish prescribed administrative procedures — Absence undermines criminal conviction
Judgment 23 April 2026
Accused’s no‑case submission dismissed; prosecution proved prima facie corruption charge and accused placed on defence.
  • Criminal law — Corruption — Prima facie proof and corroboration under Anti‑Corruption Act s6(3) — Application of Japau/Galbraith tests
  • Criminal procedure — No‑case submission — Whether prosecution evidence is so weak or unreliable that the case must be stopped — Criminal Procedure Code s207
Judgment 20 April 2026
Substitution of disciplinary charge valid if offences share same ingredients; excess leave forfeited; pension refund limited to employee contributions.
  • Disciplinary law — Acting Director-General — Proper disciplinary body — Substitution of charge — Natural justice — Accrued leave limits under conditions of service — Pension entitlements on dismissal
Judgment 31 March 2026
Owner convicted for selling a restricted vehicle without ACC consent; alleged agent acquitted for lack of notice knowledge.
  • Anti‑corruption law — Section 61(1) and (5) — restriction notices as asset‑freezing tools — service and knowledge of notice — disposal without DG consent — burden of proof beyond reasonable doubt — third party/agent liability
Judgment 26 February 2026
Accused acquitted on two corruption counts because prosecution failed to prove the alleged donor identified in the indictment.
  • Anti‑corruption — Corrupt practices with a private body — solicitation and receipt of cash gratification — digital forensic WhatsApp evidence and bank records — corroboration of an intermediary witness — failure to prove identity of alleged donor as charged.
Judgment 2 February 2026
A constitutional petition cannot reopen issues already finally decided by the Supreme Court; the appellant lacked locus standi.
  • Constitutional petitions — Article 28(1)(a) — Procedure — Order 3 Rule 2 (High Court Rules) not a basis for final dismissal of constitutional petitions — inherent jurisdiction to determine locus standi, res judicata and abuse of process — forfeiture under Corrupt Practices (Disposal of Recovered Property) Regulations — effect of a prior Supreme Court determination.
Judgment 28 January 2026
Late subpoena application refused for non-compliance with Rule 7's 14-day disclosure requirement; pre-defence conference ordered.
  • Criminal procedure — subpoena duces tecum (s.143 CPC) — Economic and Financial Crimes Court Rules — Rule 7(1) 14‑day disclosure deadline — judicial discretion to extend time — strict adherence to expedited procedure.
Judgment 21 January 2026
A court interpreter convicted for soliciting and receiving a bribe to influence a judicial outcome.
  • Corrupt practices by public officer — solicitation and receipt of gratification — recorded telephone conversations and telecom transfer records as supporting evidence — gratification as inducement or reward — burden of proof beyond reasonable doubt — Judiciary as public body
Judgment 19 November 2025
Removal of an accused does not require fresh DPP consent if charges against remaining accused remain unchanged.
  • Anti-Corruption Commission Act s64 — DPP consent to prosecute — Effect of discharge/removal of an accused on existing consent — No fresh consent required where substantive charges unchanged; pleas not rendered nullity.
Judgment 17 November 2025
Court granted subpoenas for finance and health ministry records but dismissed unrelated document requests; filing extension deferred.
  • Criminal procedure — Subpoena duces tecum/ad testificandum — Section 143 CPC — requirement of relevance and sufficient description of documents — Economic and Financial Crimes Court Rules — variation of time to file defence bundle.
Judgment 21 October 2025
Whether a director who recommended cancellation, but lacked approval authority, can be convicted for wilful procurement breaches.
  • Procurement law
    • — Contract termination — Regulation 219 requires prior authorisation by approvals authority
    • — Use of imprest — Mode of payment vs procurement method; running concurrent procurement processes unlawful
  • Anti‑Corruption — Wilful failure to comply with procedure — Proof beyond reasonable doubt; distinction between recommender and approvals authority
Judgment 7 October 2025
Court found prima facie breaches of procurement law and put accused on their defence.
  • Criminal procedure — No case to answer (Japau test); Public procurement — requisition requirement; limited bidding — requirement to record reasons; contract termination — required approvals; solicitation and evaluation — mandatory methodology and post‑qualification records.
Judgment 1 September 2025
Warrant of seizure under the Anti‑Corruption Act is temporary; prolonged unjustified freezing of funds requires discharge.
  • Anti‑corruption seizures — section 58 warrant as temporary investigative custody — section 75 does not import Forfeiture Act time limits — seizure cannot be indefinite — High Court jurisdiction where value exceeds Subordinate Court limits — remedy: discharge where unjustified prolonged retention.
Judgment 13 June 2025
Court admitted secondary copies where originals were not found after an adequate search by a competent procurement witness.
  • Secondary evidence — admissibility of copies where originals unavailable — authentication by inspection — custody/possession of documents — standard of diligence in search (George Bienga).
Judgment 8 June 2025
Non‑conviction forfeiture granted where unexplained disproportionate wealth and unregistered agreement failed to rebut reasonable suspicion.
  • Forfeiture — Non‑conviction civil forfeiture under Sections 29 and 31; Section 71 (possession suspected proceeds) as basis for reasonable suspicion; burden and standard of proof — balance of probabilities; evidential shift to interested party to prove legitimate source; unregistered land use agreement void under Lands and Deeds Registry Act; formal defects curable; property forfeited.
Judgment 28 March 2025
Applicant must prove tainted property on a balance of probabilities; suspicion of foreign wrongdoing is insufficient.
  • Forfeiture — civil (non‑conviction) forfeiture — burden of proof on public prosecutor — 'tainted property' must be proved on balance of probabilities — mere reasonable suspicion or unparticularised foreign investigations insufficient — Section 29, 30(b), 31 and 34 Forfeiture of Proceeds of Crime Act.
Judgment 24 March 2025
Applicant’s failure to serve and publish the Notice of Application as ordered led to dismissal for non‑compliance with court directions.
  • Forfeiture proceedings — service of process — compliance with court directions — Notice of Application vs Notice of Hearing — requirement to seek leave for late service — Article 118(2)(e) and technicalities — dismissal for non‑compliance.
Judgment 18 March 2025
Constitutional values alone do not found Constitutional Court jurisdiction; a specific constitutional question is required.
  • Constitutional jurisdiction — limits of Constitutional Court — national values and principles (Arts. 173, 216) not independently justiciable — interpretation vs. administrative/judicial review — requirement for specific constitutional question to invoke jurisdiction.
Judgment 6 February 2025
Civil forfeiture is governed by civil procedure; Section 11 (conviction‑based) does not authorize State possession without court process; conditional stay granted.
  • Forfeiture law — distinction between conviction‑based and civil forfeiture; Section 11 interpretation; civil forfeiture governed by civil procedure — writs and possession; propriety of counsel deposing to affidavits; stay of execution pending appeal — prospects of success and irreparable harm.
Judgment 22 January 2025
Court ordered non‑conviction forfeiture after finding reasonable suspicion of proceeds of crime and interested parties failed to rebut evidence.
  • Forfeiture (civil/non‑conviction) — Forfeiture of Proceeds of Crime Act — reasonable suspicion standard — evidentiary burden shifts to interested party to prove lawful source — bank cash deposits, disproportionate assets v. declared income — scope of subject property (subdivision vs whole title) — government bonds, treasury bills and fixed deposits amenable to forfeiture when traceable to suspected proceeds.
Judgment 20 December 2024
Court admitted a mixed-content bank credit file as evidence, holding proper foundation by the custodian suffices under Section 4.
  • Evidence — Documentary evidence — Admission of business records under Section 4 Evidence Act — Mixed originals and copies admissible with proper foundation — Custodian witness — George Bienga authority — Bank mandate file practice.
Judgment 26 November 2024
Conviction for theft by public servant quashed for lack of evidence proving possession and intent.
  • Criminal Law — Theft by Public Servant — Proof of possession and fraudulent intention required — Prima facie case under Criminal Procedure Code ss 206–207 — Penal Code s 272
Judgment 20 November 2024
Application to expunge affidavit passages and grant leave to appeal over refusal to allow examination of summoned witnesses in forfeiture proceedings.
  • Civil procedure — Affidavit evidence — Limits on affidavits (opinion, legal argument, speculation) — Expungement under Order 41 White Book; Forfeiture proceedings — oral evidence vs affidavit procedure — legitimate expectation to call witnesses; Leave to appeal — realistic prospects of success and questions of public importance.
Judgment 4 November 2024
Civil non‑conviction forfeiture application alleging Simonga Farm was acquired with proceeds of corruption; key issues include tainted property, proof standard, and proprietary interests.
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Judgment 31 October 2024
Order 20 Rule 11 cannot be used to expand a judgment to grant substantive, unpleaded reliefs.
  • Slip rule (Order 20 r.11) — correction of clerical mistakes or accidental slips only — cannot be used to grant unpleaded substantive relief; pleadings define reliefs; court functus officio after judgment.
Judgment 30 October 2024
Leave granted because non‑conviction forfeiture issues raise points of law of public importance.
  • Non‑conviction asset forfeiture — admissibility of evidence from criminal investigations in civil forfeiture — burden of proof under s33 FPOCA — individual culpability — leave to appeal under s13.
Judgment 7 October 2024
A subordinate court cannot state a case under section 341 during an ongoing trial; SI No.10/2024 does not oust jurisdiction.
  • Criminal procedure — Section 341 CPC — Case stated may only be made after hearing and determination — Timing of case-stated procedure — Statutory Instrument No.10/2024 Rule 3 — Effluxion of time does not automatically oust subordinate court jurisdiction — Frivolous/dilatory applications.
Judgment 6 October 2024
High Court dismissed application for want of jurisdiction to challenge a subordinate court's warrant of seizure.
  • Jurisdiction — challenge to warrant of seizure issued by Subordinate Court — High Court’s (Economic and Financial Crimes Division) jurisdiction is broad but not limitless — court orders subsist until set aside by issuing court — absence of challenge in issuing court bars High Court determination — matter dismissed for want of jurisdiction.
Judgment 30 September 2024
Non-conviction forfeiture allowed where applicant proves reasonable suspicion from income–asset disparity; interested party failed to rebut on balance of probabilities.
  • Non-conviction forfeiture — admissibility of electronic bank records and valuation reports — reasonable suspicion based on unexplained wealth/income-asset disparity — burden and standard of proof in forfeiture proceedings — Section 31(2) interest defence — investigating officer evidence on financial analysis.
Judgment 27 September 2024
The court dismissed the applicants' jurisdictional challenge as res judicata and warned against unlawful access to court records.
  • Jurisdiction — Economic and Financial Crimes Court; transfer of matter — abatement by effluxion of time; res judicata and abuse of process; access to court records — Section 50 Subordinate Courts Act.
Judgment 26 September 2024
Court extended the five‑month trial limit by 45 days under Rule 3(2) and refused a constitutional referral; trial to continue.
  • Criminal procedure — Statutory time limits (S.I
  • No.10/2024 Rule 3) — Commencement and computation of five‑month limit — Extension under Rule 3(2) — Jurisdiction not automatically lost on expiry — Constitutional reference unnecessary
Judgment 3 September 2024
Court ordered civil forfeiture of assets acquired from contracts obtained by false pretences; interested parties failed to rebut taint.
  • Forfeiture of proceeds of crime — Non-conviction forfeiture — jurisdiction under Sections 29, 31, 71 FPOCA — civil standard (balance of probabilities) — procurement misrepresentation — Key Personnel requirement — false pretences (Penal Code s309) — proceeds of crime — burden shift and unexplained wealth — forfeiture and costs.
Judgment 21 August 2024
Court granted the State leave to amend prosecution witness and document lists under Rule 5(6), finding no fatal prejudice to the defence.
  • Criminal procedure — Economic and Financial Crimes Court Rules 2024 — Rule 5(6) — Amendment of prosecution witness and document lists — Disclosure obligations — Prejudice to defence — Leave to amend.
Judgment 21 August 2024
Court convicted the accused of possessing assets suspected as proceeds of crime and of obtaining subsistence allowances by false pretences.
  • Forfeiture of proceeds of crime — possession of property reasonably suspected of being proceeds — reasonable suspicion based on articulable facts and asset/income disparity; evidential burden on accused who testifies; exclusion of defence material for non‑compliance with SI No.10/2024 disclosure rules; false pretences for subsistence allowances proven by absence of corroborating activity reports and phone-location evidence.
Judgment 26 July 2024
A statutory anti‑corruption agency may be a "public prosecutor" and taint of property must be decided on full evidence, not interlocutory review.
  • Forfeiture law — public prosecutor — statutory anti‑corruption agency as prosecutor; Forfeiture proceedings — tainted property — merits issue not for interlocutory determination; Civil forfeiture — non‑conviction based — parallel to criminal proceedings; Abuse of process — forum shopping — not established by concurrent civil and criminal actions; Costs — discretionary; parties to bear own costs due to novel issues.
Judgment 22 July 2024
Failure to serve the person with a fresh third‑party Restriction Notice renders it void; warrant of seizure lawful and ACC may investigate PTT.
  • Anti‑corruption investigations — Section 61 third‑party restriction notices — service requirements — validity; Distinction between Restriction Notice and Warrant of Seizure — custody vs status quo; ACC powers under s.6(1)(b) to investigate offences under other written laws including Property Transfer Tax; judicial restraint in civil proceedings that would arrest ongoing criminal investigations.
Judgment 21 June 2024
Civil NCB forfeiture requires statutory notice and proof linking property to crime; criminal cautions demand voluntariness safeguards.
  • Forfeiture of proceeds of crime — Non-conviction (in rem) forfeiture — FPOCA notice requirements (s30) — Service out of jurisdiction vs statutory notice — Admissibility of warn and caution statements obtained in criminal investigations in civil forfeiture — Voluntariness and probative weight — Two-stage test for tainted property — Standard of proof: balance of probabilities.
Judgment 11 June 2024
Failure to give statutorily required notice and lack of evidence connecting property to crime invalidated non-conviction forfeiture.
  • Forfeiture of proceeds of crime — Non-conviction forfeiture — Mandatory notice under s30 — "Tainted property" definition and burden on balance of probabilities — Inadmissibility/insufficiency of intelligence evidence — Improper focus on financial capacity.
Judgment 11 June 2024
Court granted non‑conviction forfeiture of assets as proceeds of crime and declared victim's entitlement to restitution from disposal proceeds.
  • Non-conviction forfeiture; Forfeiture of Proceeds of Crime Act — tainted property and proceeds of crime; civil standard (balance of probabilities) in forfeiture proceedings; victim's declaration of interest and restitution; recognition of equitable/beneficial interest where legal title in third party.
Judgment 15 May 2024
A witness statement does not replace oral examination in chief; it is a disclosure tool and may assist cross-examination.
  • Criminal procedure — witness statements — not standalone evidence — examination-in-chief under Criminal Procedure Code remains required — Statutory Instrument No.10 of 2024 cannot displace primary legislation — disclosure and cross-examination — Simon Miyoba v The People.
Judgment 15 May 2024
Applicant failed to show fresh evidence or compliance with mandatory Section 30(a) service requirements; review application dismissed.
  • Procedure — Review of own judgment under Order XXXIX Rule 1 — Fresh evidence test (materiality, effect, existence before decision, discovery after decision, due diligence) — Mandatory service requirements under Section 30(a) Forfeiture of Proceeds of Crime Act — Originating notice must be served with affidavit and skeleton arguments.
Judgment 10 May 2024
Public officers convicted for theft after audit, torn exhibit register page, and unexplained shortage of seized funds.
  • Criminal Law — Theft by Public Servant — Misappropriation of cash exhibits deposited in custody — Penal Code s 277
  • Evidence
    • — Exhibit registers and ACC Form 12 — Admissibility and weight of register entries and audit reports
    • — Tampered record (ripped page) — Adverse inference and circumstantial proof of intent to permanently deprive
Judgment 8 May 2024
Court held EFCC Division rules apply to pending cases and dismissed the jurisdictional challenge as unmeritorious.
  • Criminal procedure — jurisdiction of Economic and Financial Crimes Division — SI No.10/2024 (E&F Crimes Rules) — Rule 17 retrospective application to pending proceedings — cause-listing by National Prosecution Authority — disclosure and fair trial — procedural challenge inappropriate to delay proceedings.
Judgment 3 May 2024
Whether non‑conviction civil forfeiture is warranted where property value far exceeds the proprietor's known income.
  • Non‑conviction forfeiture; tainted property and proceeds of crime; burden shifting to interested party under s.31(2) FPOCA; admissibility/curability of affidavit/form defects; compatibility with constitutional property rights (Article 16).
Judgment 16 April 2024
Appellants convicted for theft by fraudulent conversion; immunity rejected; statutory judgment set aside; interest to be paid to Treasury.
  • Criminal law — Theft by public servant — Theft may be by taking or by fraudulent conversion — Particulars of charge sufficient; conversion established. Prosecutorial misconduct — Alleged witness tampering not substantiated. Statutory immunity — Sections 90 & 10 Postal Services Act inapplicable where acts not in good faith and lacking required approvals. Directors' liability — Directors may be criminally liable where they direct the mind of a corporate body. Section 171(1)(a) Criminal Procedure Code — Statutory judgment unsuitable where principal funds were paid; interest to be determined and remitted to Treasury
Judgment 15 March 2024
Court refused a rejoinder and cross-examination, finding affidavit evidence sufficient for an in rem forfeiture hearing.
  • Forfeiture in rem — procedure — clarifying/rejoinder affidavits — reply/rejoinder generally reserved for applicant; cross-examination of affidavit deponents — discretionary and exceptional; test: insufficiency of affidavit evidence, existence of contentious factual issues, and good and convincing reasons to subpoena; Section 31(2) burden for interested parties to prove legitimate interest.
Judgment 7 March 2024
Court acquitted the Project Manager of abuse of office but convicted the Site Engineer and contractor for corrupt gratification.
  • Abuse of office; corrupt practices (receipt and giving of gratification); evidential value of bank records and deposit slips; procurement/payment authorisation and thresholds; burden and standard of proof.
Judgment 1 March 2024