High Court of Malawi - 2001

107 judgments

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107 judgments
Citation
Judgment date
December 2001
Appeal against armed robbery conviction and eight-year sentence dismissed; alibi not pleaded and evidence was sufficient.
Criminal law – armed robbery – alibi defence and burden of proof – use and weight of co-accused statements under caution – corroborative physical evidence – sentence proportionality for aggravated robbery.
21 December 2001
Court refused transfer under s.75; reprosecution allowed and trial ordered at original Mzuzu venue.
Criminal procedure – Venue and transfer of trial (s.75 CP&EC) – Requirement to show fair and impartial inquiry impossible – Discharge under s.77(1) not a bar to reprosecution – Convenience of accused and witnesses – Security measures versus transfer.
11 December 2001
Court refused applicant's transfer application; respondent's discharge under s77(1) did not bar fresh prosecution.
Criminal procedure – transfer of venue (s75(1)(a)(ii), s75(3)) – discharge under s77(1) not a bar to fresh prosecution – balancing convenience of accused/witnesses and security measures
10 December 2001
Employer's seizure of former employee's household goods amounted to conversion; damages to be assessed, costs awarded to applicant.
Conversion – Seizure of former employee's household goods – Ownership and entitlement to possession – Lien and set-off versus wrongful taking – Failure to appear; trial proceeded in absence under Order 35 r.1(2) – Damages to be assessed by Registrar – Costs to plaintiff.
10 December 2001
An instalment-payment affidavit is not a s.3(1)(f) bankruptcy declaration; the court cannot extend the s.6(1)(c) three‑month limit.
Bankruptcy — s.3(1)(f) declaration — Rule 98/Form 2 compliance — s.6(1)(c) three‑month limitation — Rule 315 cannot extend statutory time — extension order void ab initio
10 December 2001
Court set aside improper statutory registration of a South African magistrate's judgment and ordered common-law commencement.
Enforcement of foreign judgments; territorial extension of British and Commonwealth Judgements Act; requirement of superior court judgments; procedural irregularities treated under Order 2; common-law action by writ to enforce foreign judgments; defences to foreign judgments (fraud, public policy, natural justice)
9 December 2001
Employer’s seizure and retention of ex‑employee’s goods after pension recovery constituted conversion; damages to be assessed.
Conversion – ownership and entitlement to possession – wrongful taking and retention of chattels – lien and debt recovery – damages to be assessed by Registrar – costs awarded
9 December 2001
Divorce granted where respondent committed adultery, cruelty and constructive desertion; ancillary relief deferred for separate hearing.
Matrimonial law - Divorce grounds: adultery (inference from cohabitation and child), cruelty (single act suffices), constructive desertion; collusion in undefended petitions; jurisdiction/domicile; custody, maintenance and property division deferred to chambers
9 December 2001
Adultery inferred from cohabitation justified divorce; custody, maintenance and costs awarded to the petitioner.
Divorce — Adultery — Proof by inference from cohabitation and conduct; standard of proof: balance of probabilities — Collusion/condonation — Jurisdiction: domicile — Custody and maintenance endorsement — Costs follow the event (no limit).
5 December 2001
Both drivers were negligent: defendant for improper parking without warnings, plaintiff’s driver for excessive speed; liability apportioned 50/50.
Road traffic negligence – duty of care of drivers – negligent parking on or near road without warning – contributory negligence by excessive speed and failure to keep proper lookout – apportionment of liability 50:50.
3 December 2001
November 2001
Plaintiff awarded compensatory damages for workplace negligence causing loss of three fingers and reduced earning capacity.
Negligence - workplace injury - assessment of damages in defendant's absence - heads of damage: pain and suffering, loss of amenities, disfigurement, loss of earning capacity - prior compensation inadequate
29 November 2001
Interim injunction upheld in judicial review; Section 10 does not bar injunctions protecting constitutional rights.
Judicial review – interlocutory injunctions – Section 10 Cap. 6:01 – constitutional remedy – Speaker as party to review – ex parte non-disclosure – American Cyanamid balance of convenience.
27 November 2001
Court continued interim injunction in judicial review, holding Section 10 Cap.6:01 does not bar injunctions protecting constitutional rights.
Judicial review – interlocutory injunction against Speaker/Attorney General – applicability of Civil Procedure (Suits by or Against Government) Act s.10 – constitutional power to grant effective remedies – Speaker must be party where declaratory relief is sought – American Cyanamid principles applied
26 November 2001
Plaintiff awarded lost salary, commuted leave and death gratuity; housing allowance refused; interest from 21 May 1994 at 25% p.a.; costs awarded.
Civil service — Wrongful dismissal — Assessment of lost salary, commuted leave and death gratuity; refusal of housing/ancillary allowances absent contractual entitlement; interest on judgment debts — discretionary award from effective date of entitlement at 25% p.a. simple interest.
23 November 2001
A summons for security for costs does not stay proceedings; plaintiff validly entered default judgment, so security application dismissed.
Civil procedure – security for costs (Order 23) – foreign plaintiff – effect of summons for security on proceedings – default judgment – setting aside default judgment – post-judgment security only where judgment directs further proceedings.
22 November 2001
Court refused injunction preventing mortgagee’s contractual power of sale; plaintiff lacked a good arguable case.
Civil procedure – interlocutory injunction – application of American Cyanamid test; Mortgage law – contractual power of sale – courts reluctant to restrain a bona fide exercise of power of sale under a legal charge.
9 November 2001
Assessment of damages for an 11‑year‑old’s death: K20,000 for life expectancy loss and K15,000 for dependency, plus costs.
Damages – death of child – assessment of loss of expectation of life and dependency – quantum for infants versus adolescents – conventional awards guided by precedent.
7 November 2001
October 2001
Court found quo warranto-equivalent relief available, a triable issue existed, and granted an interim injunction to preserve the status quo.
Constitutional & administrative law – quo warranto and injunctive relief – received English statutes as Malawi law – procedure: judicial review v ordinary action (O'Reilly v Mackman exceptions) – res judicata and adequacy of damages – balance of convenience for interlocutory injunction
21 October 2001
High Court has concurrent jurisdiction over many labour disputes; Industrial Relations Court’s jurisdiction is limited and does not oust ordinary courts.
Constitutional jurisdiction of High Court – Concurrent jurisdiction with Industrial Relations Court – Limits of Industrial Relations Court’s jurisdiction under Labour Relations Act and Employment Act – Distinction between statutory unfair dismissal and common-law contractual/tort remedies – Transfer versus dismissal of proceedings – Injunctive relief in labour disputes.
16 October 2001
Interlocutory injunction to restrain alleged subletting was justified to preserve the status quo pending trial.
Interlocutory injunction — preservation of status quo pending trial — advertisement as evidence of intention to sublet or transfer — tenancy at will v. subsisting lease — successor in title’s rights and consent to subletting — weight of prior interlocutory findings.
14 October 2001
A confession by one accused is not evidence against another; students need proof of an arrangement to be guilty under s57.
Education Act s57 – possession and communication/use of examination papers; admissibility of confession only against maker unless adopted; hearsay inadmissible; students cannot be convicted absent evidence of arrangement to be principals
11 October 2001
Interlocutory injunction upheld to prevent tenant's potential subletting or transfer without landlord's consent pending trial.
Interlocutory injunction – preservation of status quo pending trial; advertisement as indication of intended subletting/assignment; tenant-at-will versus tenancy; requirement of landlord's written consent for subletting/transfer; successor-in-title rights; prior interlocutory orders not final
3 October 2001
Interlocutory injunction restraining sale vacated where Registered Land Act transfer cured irregularities and damages are adequate.
Interim injunction — Registered Land Act (s.68, s.71(3)) — sale by chargee — transfer/Registrar’s certificate cures irregularities — American Cyanamid principles — adequacy of damages as remedy
2 October 2001
Young children, including a 1½-year-old, do not automatically constitute exceptional circumstances to warrant bail in a homicide case.
Criminal law — Bail in serious offences — Exceptional circumstances required for bail — Young children of accused not automatically exceptional; recourse under s.60 Prisons Act for unweaned infants
1 October 2001
September 2001
Court granted divorce for proven cruelty (habitual drunkenness and violence), awarded custody to petitioner and ordered respondent to pay costs.
Family law – Divorce for cruelty – habitual intoxication and violence as matrimonial offence – petitioner’s sole evidence accepted – decree nisi granted; custody to petitioner; respondent to pay costs – comparative reference to Divorce Reform Act 1969; need for reform of Divorce Act and customary family law procedures
30 September 2001
Conviction for indecent assault of a child under 14 is unsafe without corroboration; conflicting medical reports created reasonable doubt.
Criminal law – Sexual offences – Evidence of child complainant under 14 requires corroboration – Medical evidence as corroboration – Conflicting medical reports render conviction unsafe.
28 September 2001
Missing trial record and uncertain appeal date do not by themselves constitute exceptional circumstances for bail pending appeal.
Criminal procedure – Post-conviction bail – Exceptional circumstances required – Missing trial record and uncertain appeal date do not alone justify bail – Right of appeal; administrative lapse
26 September 2001
An acquitted public servant was awarded damages for false imprisonment and malicious prosecution and recovery of withheld salary.
False imprisonment – short detention with ill-treatment – damages assessed; Malicious prosecution – acquittal entitles plaintiff to damages; Employment law – withheld salary after acquittal cannot lawfully be forfeited; Remedies – award of wages withheld plus costs where defendant defaulted.
25 September 2001
Power of sale valid after three months; private treaty sales lawful if in good faith; irregularities yield damages only.
Registered Land Act – demand notice and default (s68) – power of sale after three months (ss60(2),68(2)) – sale by private treaty valid if in good faith (s71) – Registrar approval not strictly fatal – remedy for irregularity is damages (s71(3)).
20 September 2001
Conviction for conspiracy quashed where court improperly relied on co-accused confessions and failed to prove a single agreement.
Criminal law – Conspiracy – Admissibility and weight of confessions under s176 Criminal Procedure and Evidence Code – Confessions admissible only against maker unless adopted – Statements to police not in furtherance of conspiracy (res gestae) – Confessions obtained by duress/torture inadmissible or to be given no weight – Burden to prove single agreement among accused.
19 September 2001
Interim injunction granted to restrain defendant’s occupation of disputed land; widow-signed sale document deemed invalid under Statute of Frauds.
Land law – interim injunction – trespass and occupation – beneficiary’s locus standi to sue – Statute of Frauds 1677 – validity of purported sale document signed by widow – balance of convenience and irreparable harm.
18 September 2001
Convictions quashed because the appellants' confessions could not be used against co-accused and no single conspiracy was proved.
Criminal law – Conspiracy: requirement of proof of a single agreement among alleged conspirators; Confessions/Caution statements – admissible only against maker unless adopted; statements obtained by torture/duress must be given no weight; section 176 Criminal Procedure and Evidence Code; hearsay/res gestae exceptions; appellate reversal for insufficient evidence
18 September 2001
August 2001
Adjourning a contempt hearing to another day deprives the court of summary jurisdiction, rendering any subsequent conviction a nullity.
Contempt of court – Summary jurisdiction lost by adjournment – Requirement to warn potential contemnor before summary charge – Need for formal charge sheet and avoidance of duplicity – Procedural defects render conviction a nullity – Sections 113 Penal Code; Sections 353(2)(a)(i) and 362 Criminal Procedure and Evidence Code.
31 August 2001
High Court lacks first-instance jurisdiction over Employment Act labour disputes; such claims belong in the Industrial Relations Court.
Employment law — jurisdiction — High Court's unlimited original jurisdiction (s108) does not displace the Industrial Relations Court's primary procedural role for employment disputes; severance pay — forum — defective commencement — dismissal, not transfer
30 August 2001
Five-month imprisonment for breach-of-peace offence was unlawful; court ordered immediate release.
Criminal law – Sentence review – Section 181 Penal Code (conduct likely to cause breach of the peace) – statutory maximum custody three months – “fine and imprisonment” read disjunctively – failure to consider fine, community service, and Sections 339–340 alternatives – review court substituted sentence for immediate release
30 August 2001
The applicant's illness and alleged alibi do not constitute exceptional circumstances to grant bail in a murder charge.
Criminal procedure — Bail in capital offences — Exceptional circumstances required; illness not exceptional unless terminal or detention-induced; alibi or weak prosecution case insufficient; bail applications must not become mini-trials
29 August 2001
An interlocutory injunction preventing an employer recovering company property was discharged as damages were an adequate remedy after termination.
Interlocutory injunctions – American Cyanamid principles – adequacy of damages as remedy – ex parte applications and nondisclosure/misrepresentation – employer’s right to recover company property after employment termination – publication of notice that employee no longer occupies post.
24 August 2001
Order 14 summary disposal refused because the disputed cause of the accident was a factual issue requiring a full trial.
Civil procedure — Order 14 summary disposal — question of law v. fact; Workers Compensation Act s.4(2)(b) — negligence, deliberate self-injury, serious and willful misconduct; requirement of evidence for exclusions under compensation statute.
23 August 2001
Ex parte interlocutory injunction discharged where applicant deliberately suppressed material facts and misled the court.
Civil procedure – Ex parte interlocutory injunction – Duty of full and frank disclosure – Suppression of material facts – Order obtained by misrepresentation discharged.
22 August 2001
Sheriff’s fees (poundage) are due once goods are seized; the party who caused execution is liable even if no sale occurs.
Sheriff’s fees/poundage — entitlement upon seizure of goods — execution levied but no sale — Courts Act Schedule; Sheriffs Act; local precedents (Maunde; Sheriff v Press Produce) — Re Ludmore distinguished — liability of party initiating execution — court power to order payment of Sheriff’s costs when setting aside execution.
17 August 2001
Hearing set aside because plaintiff failed to provide for acknowledgment of service and allowed insufficient time after postal service.
Civil procedure – Originating Summons (Order 7 r.2, Form 10) – requirement to provide for acknowledgment of service and to serve acknowledgment form – postal service deemed effective after seven days – premature hearing where defendant not given full time to acknowledge service – power to set aside hearing and direct amendment
9 August 2001
July 2001
A conditional offer that failed to arise prevented contract formation; claim dismissed and defendant awarded costs.
'Contract law' – conditional offer; formation of contract; sale of goods; acceptance; burden and standard of proof; costs follow the event
29 July 2001
Assessment of wrongful-death damages: awards for loss of expectation and dependency, apportionment, and minors' shares lodged in court.
Wrongful death — assessment of damages — loss of expectation of life; loss of dependency — multiplicand and multiplier method; one-third deduction; apportionment among dependants; minors' shares to be paid into court.
18 July 2001
Court dismissed an oral Order 14A summary application, finding disputed facts and improper procedure; case to proceed to trial.
Defamation (libel) – qualified privilege – publication admitted by newspaper – Order 14A summary disposal – procedural requirement that disputed factual issues be resolved at trial – oral Order 14A application at final hearing improper
15 July 2001
Interim injunction granted in a passing-off claim where damages inadequate and balance of convenience favoured the applicant.
Passing off; interlocutory injunctions (American Cyanamid principles); adequacy of damages in passing-off claims; balance of convenience/incidence of injustice; billboard advertising confusion.
15 July 2001
Oral Order 14A disposal at trial refused where disputed factual issues and procedural requirements necessitated a full trial.
Defamation — publication by newspaper — qualified privilege defence; Order 14A applications — suitability and procedure; necessity to prove disputed facts at trial when defendant absent
15 July 2001
A spouse has standing to challenge deportation; deportation unlawful where statutory visa-exemption and procedural safeguards ignored.
Constitutional law – standing under s15(2) and s46 – broad ‘sufficient interest’ test; Administrative law – duty to give written reasons and notification of appeal; Immigration law – visa-exemption schedule for Nigerian nationals; Judicial review – Wednesbury unreasonableness; Family rights – consideration of marital/consortium interests in immigration decisions
7 July 2001
Wrongful but clear termination entitles the applicant to notice pay; overtime and accrued leave awarded, other claims denied.
Employment law – wrongful but clear termination – contractual requirement of one month's notice or pay in lieu – termination effective despite breach – damages limited to notice period – entitlement to unpaid overtime and accrued leave – insufficient proof for additional pension refund
3 July 2001
Employer vicariously liable for guards' battery and false imprisonment; bicycle trespass proven; K60,000 awarded.
Tort — Battery and false imprisonment by security guards; vicarious liability of employer; trespass to chattel (bicycle); assessment and quantum of damages; absence of defendant at trial
1 July 2001
June 2001
Court allowed defendant to amend defence to add specific performance claim, ordered amended pleadings within 40 days and costs on defendant.
Civil procedure – Amendment of pleadings – Leave to amend defence and counterclaim to include specific performance – Summary judgment under Order 86 rule 8 – Prejudice and costs – Discretion to allow amendments at hearing stage.
26 June 2001