Corruption, Fraud and Illicit Money Flows

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Corruption, Fraud and Illicit Money Flows

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85 documents
A Section 80 settlement registered before later prosecution bars prosecution until a court discharges the agreement.
  • Anti-Corruption Act s80 — settlement undertakings — timing of institution of criminal proceedings — immunity from prosecution — discharge of undertaking via Subordinate Court (s80(4), s86).
Judgment 15 November 2023
Whether the prosecution proved that the accused, a public servant, fraudulently moved and sold government containers.
  • Criminal law — Theft by public servant — Elements: actus reus (taking/movement) and mens rea (fraudulent intent) — Proof that property belonged to Government — Evidential corroboration of witness testimony and transactions — Disposal of government assets and role of Ministry of Works and Supply.
Judgment 23 March 2023
An s.80 Anti‑Corruption Commission undertaking cannot bar prosecution once criminal proceedings have commenced.
  • Criminal procedure — Section 80(3) Anti-Corruption Act — undertaking not to institute criminal proceedings — applies only before prosecution is commenced; autrefois acquit/double jeopardy — requires prior trial and acquittal — registered undertaking is not an acquittal; nolle prosequi distinguished; appeal allowed and matter remitted for rehearing.
Judgment 10 November 2022
A s58 warrant under the Anti‑Corruption Act attracts criminal jurisdiction; the High Court may grant an out‑of‑time appeal without hearing the parties.
  • Anti‑Corruption Act s58 — seizure warrants; criminal jurisdiction; interplay with Criminal Procedure Code (s2, s321A, s322 proviso, s324); out‑of‑time appeals; High Court discretion; procedural misdirection by subordinate court.
Judgment 30 August 2022
Documents like registration extracts and bills of lading need not be authenticated under the Act; claimant established pre‑offence interest, so forfeiture set aside.
  • Forfeiture of proceeds of crime — third‑party claims under ss.12(2) and 31(2) — proof of interest and timing of acquisition — Authentication of Documents Act — what constitutes a document requiring authentication — burden of proof on claimant.
Judgment 28 July 2022
Plaintiff must specify defamatory words and correct inconsistent/unstated damage claims or face dismissal; exemplary/aggravated damages must be specifically pleaded.
  • Civil procedure — Order 14A preliminary issues; Defamation — requirement to plead words complained of (Order 18, Rule 7); Libel by schedule — leave required; Pleadings — embarrassing/inconsistent endorsements; Distinction between liquidated and unliquidated claims; Requirement to specifically plead exemplary and aggravated damages (Order 18, Rule 12).
Judgment 27 May 2022
Warrant of seizure set aside because supporting affidavit was not filed and the instrument lacked any directive, amounting to abuse of process.
  • Anti-Corruption Act — seizure warrants — supporting affidavit must be filed (Order 5 r.11 Subordinate Court Rules) — warrant must contain directive to seize — material defect under Forfeiture of Proceeds of Crime Act s35 — restriction notice v. warrant — abuse of process.
Judgment 19 May 2022
Court upholds civil non-conviction forfeiture: vehicle used in offence was tainted and claimant lacked sufficient interest to resist forfeiture.
  • Forfeiture of proceeds of crime — non-conviction civil forfeiture under ss.29–31 FPOCA — jurisdiction and mode of commencement — definition of tainted property — claimant’s sufficient legal or equitable interest and onus under s.31(2).
Judgment 30 November 2021
Alleged forged tax clearance and proceeds-of-crime suspicions not proved; all accused acquitted.
  • Criminal law — making and uttering false documents — tax clearance certificates — authority and procedural irregularities at revenue office — obtaining pecuniary advantage by false pretences — proceeds of crime — reasonable suspicion — burden of proof — acquittal.
Judgment 9 September 2021
Bail pending appeal denied for lack of exceptional circumstances; separate stay of sale dismissed as appeal already operates as a stay.
  • Criminal procedure — bail pending appeal — exceptional circumstances required for bail; interlocutory relief — stay of sale of forfeited property — lodging criminal appeal operates as a stay; sentencing jurisdiction — contention regarding subordinate court's maximum sentence (not decided on merits).
Judgment 21 April 2021
Whether a trial court may hear forfeiture applications pending appeal and whether an appellate court can order forfeiture.
  • Forfeiture of property; Forfeiture of Proceeds of Crime Act s.11(4); Narcotic Drugs Act s.34; jurisdiction to order forfeiture; appellate court limits; third‑party claim in forfeiture proceedings.
Judgment 25 February 2021
COVID-19 alone does not constitute exceptional circumstances to grant bail pending appeal without changed prospects or risk.
  • Criminal procedure — Bail pending appeal — discretionary remedy; exceptional circumstances required — COVID-19 alone insufficient unless it materially alters prospects of success or risk of serving substantial part of sentence; prior dismissal of bail not reopened where considerations unchanged.
Judgment 16 April 2020
Subordinate Court lacked jurisdiction to grant forfeiture restraining order exceeding its civil monetary limit.
  • Jurisdiction — Subordinate Courts — Forfeiture of Proceeds of Crime Act — civil proceedings — monetary limits — lack of jurisdiction renders proceedings a nullity.
Judgment 9 September 2019
Odd coincidences can corroborate interested witnesses’ testimony and sustain a conviction for corrupt practices; sentence increased within jurisdiction.
  • Corroboration — odd coincidences as corroborative evidence; distinction between corroboration and circumstantial evidence; solicitation and constructive possession in bribery prosecutions; appellate interference with sentence within subordinate court’s jurisdiction.
Judgment 23 October 2018
Whether one‑off terminal payments on resignation qualify as constitutional 'pension benefits' and trigger payroll retention under Article 189.
  • Constitutional law — definition of "pension benefit" (Art. 266) — terminal/one‑off payments — payroll retention (Art. 189) — purposive and literal interpretation — reading Constitution as a whole — retirees/retrenchees protection.
Judgment 26 January 2018
Judgment 26 January 2018
Judgment 26 January 2018
Application to review seizure without warrant dismissed as time‑barred; extension required formal motion; criminal investigations not stayed by judicial review.
  • Judicial review — leave to apply — Order 53(4) three‑month time limit — extension of time requires formal motion and service — seizure under s.58 Anti‑Corruption Commission Act requires warrant — civil proceedings cannot be used to arrest criminal investigations.
Judgment 8 December 2017
Service on the appellant via internal channels sufficed; malice may be inferred from lack of reasonable and probable cause.
  • Civil procedure — Service on State bodies — Section 13 State Proceedings Act and s.4(2) Anti‑Corruption Act — service on officers marked for attention and pigeonhole practice; Setting aside judgment — requirement of arguable defence and explanation for default; Malicious prosecution — elements (prosecution, termination in favour, absence of reasonable and probable cause, malice, damage); Malice may be inferred from want of reasonable and probable cause; Damages for mental anguish and defence costs recoverable.
Judgment 16 October 2017
Section 49(2) imposes an evidential explanation burden but does not violate the right to silence or presumption of innocence.
  • Criminal law — Corruption offences — Presumption of innocence and right to silence — section 49(2) Anti‑Corruption Commission Act creates an evidential burden, not a compulsory duty to testify; appellate restraint in overturning trial credibility findings; sufficiency of documentary and investigative evidence (invoices, bank drafts, export docs).
Judgment 6 June 2017
Regulations validly applied: properties were "recovered", unclaimed within three months, and consequently forfeited to the State.
  • Corrupt Practices (Disposal of Recovered Property) Regulations 1986 — validity and effect; definition of "recovered property"; vesting on expiry of three-month claim period; service and claim to Commission; judicial review of forfeiture.
Judgment 29 December 2016
Article 118(2)(e) does not abolish procedural rules; sections 207 and 208 remain valid to protect fair trial and truth-finding.
  • Constitutional interpretation — Article 118(2)(e): undue regard to procedural technicalities — scope and application; Criminal Procedure Code — sections 207 & 208 — order of defence evidence; procedural rules vs technicalities; fair trial and truth-finding.
Judgment 7 November 2016
Possession of large concealed cash may ground reasonable suspicion under s71; prosecution need not prove a predicate offence.
  • Forfeiture of Proceeds of Crime Act s71 — 'may reasonably be suspected' standard — possession plus articulable facts — no need to prove predicate offence — s71(2) defence shifts evidentiary burden (balance of probabilities) — s78 indicates lower standard for factual issues
Judgment 1 June 2015
A restriction notice expired by operation of law but remained effective against the applicant because the Commission failed to notify registries to discharge it.
  • Anti‑corruption law — restriction notices under s.24(1) and (3) of ACC Act 1996 — expiry by operation of law after twelve months — duty to notify third‑party registries of expiry — continuing effect of registered notices absent notification — misfeasance in public office requires bad faith/malice
Judgment 17 June 2014
Restriction on company property was reversed where investigations targeted a shareholder personally, upholding corporate separateness.
  • Anti-Corruption Act s24(1) — Restriction notices — Requirement of on-going investigation but not specification of offence; corporate personality — company property distinct from shareholders; scope of investigations relevant to validity of restriction notice.
Judgment 6 January 2014
Restriction notices require ongoing investigations but must target the correct legal person; courts may probe investigation focus.
  • Anti-Corruption Act s24(1) — Restriction Notices — Only an on-going investigation under Part IV is required, specification of particular offence unnecessary — Corporate personality — Distinction between company and shareholders — Court may scrutinize focus of investigations to ensure Restriction Notice targets correct legal person and to prevent fishing expeditions
Judgment 5 January 2014
Whether post-qualification procurement action, supported by an insurer’s bond, constituted criminal theft or money laundering.
  • Criminal law — theft by public servant; procurement law — post-qualification evaluation and addendum requirements; evidential burden — intent to permanently deprive; money laundering dependent on predicate offence; issuing cheques — requirement of intent to defraud; adverse inference where prosecution withholds material documents (MTC minutes).
Judgment 1 November 2012
Application for judicial review dismissed: presidentially constituted Task Force lawfully comprised seconded officers retaining statutory powers.
  • Judicial review — Order 53 — Illegality, ultra vires and presidential powers — Ad hoc Task Force constitutionality — Secondment of officers retains statutory powers — Validity of call‑outs and investigations.
Judgment 9 February 2012
Court convicted the first and second accused for abuse of office and corrupt practices under the Anti‑Corruption Act.
  • Anti‑Corruption Act — abuse of office (s37(2)(a)) — corrupt practices (ss29(1),29(2)) — presumption under s49(2) — admissibility/weight of foreign invoices and bank transfer records — failure to follow public procurement/tender procedures — indirect benefit through third party (property acquisition).
Judgment 2 March 2009
Whether a re-enacted statutory instrument may govern forfeiture of property seized under a repealed instrument.
  • Statutory interpretation — repeal and re-enactment of statutory instruments — whether re-enacted provisions retain force for earlier seizures; forfeiture of recovered property — vesting in the State once statutory conditions met; retrospective effect of legislation; Interpretation and General Provisions Act (sections on re-enactment and commencement).
Judgment 14 May 2008
On review the High Court replaced a suspended sentence for grand corruption with nine months' custody and held forfeiture mandatory.
  • Criminal law — Review under sections 337–339 CPC — Sentencing for public‑office corruption — ‘Grand corruption’ and deterrent custodial sentences — Mandatory forfeiture under s.41 Anti‑Corruption Commission Act — Role of medical evidence in mitigation.
Judgment 9 March 2008
Director-General may issue fresh restriction notices and direct rental payments pending corruption investigations, subject to refund if exonerated.
  • Anti-Corruption Commission Act s24(1) — Restriction notices; investigation (not necessarily prosecution) sufficient — Fresh notices after expiry valid — "Dispose of or otherwise deal with" includes managing property (collecting rent) — Certificate of title defeasible for fraud — High Court review powers under s24(5)/(7)
Judgment 29 January 2008
A statutory requirement forcing an accused to give sworn evidence violates the constitutional protection against compulsion to give evidence.
  • Constitutional supremacy — statutory provision requiring sworn evidence (s.53(1) Corrupt Practices Act) conflicts with Art.20(7) protection against compulsion; no implied amendment of Constitution; Speaker's certificate and two-thirds majority required for constitutional amendment; absence renders conflicting provision invalid.
Judgment 13 November 1984
A statutory rule forcing sworn testimony conflicts with the constitutional right not to be compelled to give evidence and is invalid.
  • Constitutional law — supremacy of the Constitution — no implied amendment — Speaker's certificate required for special Bills — absence renders conflicting statutory provision ultra vires; Criminal procedure — right against compulsion to give evidence (Art.20(7)) — s.53(1) Corrupt Practices Act invalid and severed
Judgment 12 November 1984
The applicant’s prosecution under the Corrupt Practices Act does not contravene Article 20(4); procedural referral was properly before the High Court.
  • Criminal procedure — case stated under s.345 C.P.C. — not available before trial completion; Constitutional reference — Article 29(3) — proper referral despite procedural error; Corrupt Practices Act — retrospective criminalisation and Article 20(4) — does not create new offence; Definition of public officer — Ministers prosecutable under Penal Code via s.103A and s.94; Sentencing — minimum sentence issue noted but not decided
Judgment 6 September 1984