High Court of Malawi Commercial Division

22 judgments

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22 judgments
Citation
Judgment date
January 2026
Court holds domestic jurisdiction prevails; fresh arbitration and foreign proceedings restrained as abuse of process.
Commercial law – arbitration clause – stay of proceedings – section 6(1) Arbitration Act – jurisdiction after Supreme Court of Appeal order – anti-suit injunction – forum shopping – competence of procedural application under CPR 2017.
29 January 2026
An arbitration clause expressly excluding the escrow agent prevents the applicant from obtaining a stay pending arbitration.
Arbitration — Stay of proceedings under s.6 Arbitration Act — Arbitration clause in escrow agreement — Clause expressly excluding escrow agent — Interpretation of exclusion clause — Readiness and willingness to arbitrate required as evidentiary burden.
27 January 2026
Stay refused because contract's "arbitration" clause only required negotiation, not binding arbitration.
Arbitration law – stay of proceedings – clause headed 'ARBITRATION' construed as negotiation clause – heading cannot override clear substantive wording – requirement of valid arbitration agreement under s.6(1).
6 January 2026
December 2025
Whether a signed written K42,000,000 loan existed, was usurious under the Loans Recovery Act, and whether vehicle security must be returned.
Contract formation – existence and certainty of written loan agreement; Parol evidence rule – written document prevails; Loans Recovery Act – reopening transactions for excessive/usurious interest; Pleadings – duress/alternative claims must be specifically pleaded and proved; Security disputes – unproven vehicle security and counterclaim dismissed.
17 December 2025
Interim inhibition under s123 RLA set aside; applicant lacked arguable claim and property was not at risk.
Registered Land Act s123 – inhibition orders – discretionary preservatory relief – threshold: risk of disposition, refusal would render suit nugatory, and arguable/sustainable claim – set aside of interim inhibition where threshold not met.
12 December 2025
Court cured a defective application heading, held it retained jurisdiction to hear suspension of enforcement, and dismissed the claimant’s preliminary objection with costs.
Civil procedure – Mediation and mandatory attendance – Order 13 CPR 2017 – Default judgment for non-attendance – Restoration and suspension of enforcement under Order 28 r48 – Curable procedural defects (Order 2 r3(d)) – Functus officio rule – Preliminary objections permitted.
11 December 2025
Stay of execution denied where applicants failed to prove inability to repay and prosecution of the appeal was unduly delayed.
Stay of execution pending appeal – Order 28 r.48 CPR 2017 – applicant must show special circumstances – inability v unwillingness to pay – need for enforcement evidence (sheriff’s return) – corporate personality separates company and individual liabilities – judicial discretion and impact of undue delay.
10 December 2025
September 2025
Claimants failed to prove a binding 2022–23 seed buy‑back contract; claim dismissed and costs awarded to the defendant.
Contract formation – offer and acceptance – certainty of terms – burden of proof in civil cases – written contract alleged but not produced – registration/inspection not equivalent to contractual buy-back obligation.
2 September 2025
June 2025
A dispute arising from an insurance contract is a commercial matter and must be heard in the Commercial Division.
Commercial law — Jurisdiction — Definition of "commercial matter" — Insurance services within definition — Nature and business connection, not monetary value, determine commercial classification — High Court supervisory review and nullification of magistrate proceedings.
24 June 2025
February 2025
Claim dismissed for want of prosecution after counsel failed to renew licence and timely inform the claimant.
Civil procedure – dismissal for want of prosecution; counsel's duty to maintain valid practising licence (LELPA s30); duty to inform client and arrange alternative representation (LELPA s31(5)); adjournment discretionary; costs for prejudice caused by counsel's conduct.
6 February 2025
January 2025
27 January 2025
November 2024
Whether a High Court may lift a stay after arbitration termination and grant leave to appeal with a stay pending appeal.
Arbitration law — lifting stay of proceedings after arbitration termination — leave to appeal against interlocutory Ruling — stay pending appeal; procedural compliance with leave-to-appeal rules; commercial efficacy and overriding objective.
26 November 2024
July 2024
Court held statute (Insolvency Act) prevails over CPR; receiver appointment required notice, so enforcement suspended.
Appointment of receiver – Order 28 r.29 & r.30 CPR – s.78(1) Insolvency Act – conflict between statute and subsidiary rules – requirement of notice to company – service of statutory demand – procedural compliance with sworn statements – s.79 notification by receiver.
5 July 2024
June 2024
A late application for security for costs was dismissed where claimant rebutted jurisdictional and asset concerns and delay made the order oppressive.
Security for costs – Order 32 CPR – residence and central management – assets and enforceability of costs – delay in bringing application – prospects of success – oppressive/stifling effect.
19 June 2024
February 2024
Claimant awarded outstanding loan sums with interest; no cogent evidence of fraud; attachment of the family-home interest denied.
Commercial law — loan recovery; alleged fraud in creation of surety charge — requirement of cogent evidence for fraud; distinction between default and breach; attachment of beneficial interest in family home; exemplary damages not available for contract default; garnishee as alternative remedy.
24 February 2024
January 2024
Court discharged the 1st accused under section 247 CP & EC after the State conceded it had no evidence and could not proceed.
Criminal law — discharge of accused under section 247 CP & EC where prosecutor unable or unwilling to proceed — inapplicability of section 270 at substantive High Court trial — discontinuance power of DPP under section 77/section 99 — protection against prosecution without credible evidence.
9 January 2024
May 2023
Court set aside an irregular private-treaty sale of seized assets, ordered restitution and referrals for investigation.
Execution and Sheriff’s Act — validity of ex parte leave to sell by private treaty — statutory sale periods and public auction requirements — admissibility of untested affidavit evidence — collusion in execution process — relief: set aside sale, restitution, criminal and disciplinary referrals.
16 May 2023
April 2023
Court dismissed a claim as frivolous, vacated injunction, struck out irregular sworn statement and awarded indemnity costs.
Civil procedure – strike out for frivolous and vexatious action; Registered Land Act – power of sale exercised in good faith; interlocutory injunction procured by suppression of material facts; sworn statements must state facts not legal argument; remedy for irregular sale is damages, not injunction.
20 April 2023
March 2023
Claim against a non‑party assignee dismissed: acknowledgement letters did not create a binding guarantee, claim frivolous.
Contract law – privity of contract; assignment of proceeds – acknowledgement vs. guarantee; requirement of acceptance to bind third party; strike out for frivolous and vexatious claims.
23 March 2023
October 2021
28 October 2021
November 2020
A defendant seeking a stay must show real risk of serious prejudice; mere concurrent criminal proceedings do not justify a stay.
Civil procedure – stay of civil proceedings pending related criminal trial – applicant must show real risk of serious prejudice causing injustice; mere factual overlap insufficient; defendant not party to criminal proceedings cannot claim such prejudice; differing standards of proof between criminal and civil proceedings relevant.
30 November 2020
January 2019
An ex parte amendment that prejudices the opposing party must be set aside; costs do not cure the prejudice.
Civil procedure — Amendment of pleadings after close of pleadings — Ex parte vs inter partes amendment — Prejudice and fairness — Costs not an adequate remedy — Setting aside ex parte order.
29 January 2019