High Court of Malawi - 2003

128 judgments

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128 judgments
Citation
Judgment date
December 2003
Applicant awarded market-rental damages and assessment costs for respondent's wrongful occupation based on unchallenged valuation evidence.
Property law – Wrongful possession – Measure of damages: market rental value; assessment based on unchallenged professional valuation; award of K509,000 and costs of assessment.
31 December 2003
Letters admitting rent arrears and failure to seek a stay for arbitration led to judgment on admissions and summary judgment for the plaintiff.
Lease – rent and service-charge arrears – admission by correspondence – Order 27 r.3 (judgment on admissions) – arbitration clause – stay under Arbitration Act – failure to apply for stay – Order 14 r.1 (summary judgment) – costs.
31 December 2003
Summary judgment granted where plaintiff proved debt and defendant failed to file particulars or show a bona fide defence.
Civil procedure – Summary judgment under Order 14 – Plaintiff’s documentary proof of debt – Defendant’s failure to file defence or affidavits with particulars – No bona fide defence – Judgment with costs.
31 December 2003
Whether service at a spouse's workplace renders a default judgment irregular and if a meritorious defence warrants setting it aside.
Civil procedure — setting aside default judgment — Order 13 r 9 — service by post/last known address — service at spouse’s workplace — regularity of judgment — meritorious defence — right to trial.
31 December 2003
Assessment of general damages for assault and battery based on uncontested evidence and medical report.
Tort — Assault and battery — Assessment of general damages — Pain and suffering, loss of amenities, injury to feelings — Weight of medical report versus continued employment and outpatient treatment.
31 December 2003
Where the respondent negligently damages the applicant's vehicle, the applicant is entitled to loss-of-use damages based on reasonable hire costs.
Tort — Negligence — Motor vehicle collision — Liability for loss of use — Measure of damages for loss of use assessed by reasonable hire cost per day.
31 December 2003
Applicant awarded K457,000 for repair and loss-of-use after vehicle damaged by police officers; hire costs upheld.
Assessment of damages — Vehicle damaged by state police — Repair costs and loss-of-use hire costs — Acceptance of undisputed evidence — Award of damages and costs.
31 December 2003
Default judgment set aside for irregular service; defendant's meritorious defence found; plaintiff to pay sheriff fees.
Civil procedure – setting aside default judgment – service of process – personal service required under Order 65 r2 – third‑party acknowledgement and agency – meritorious defence – sheriff fees (s.44(3) Sheriff Act).
31 December 2003
Summary judgment refused where genuine disputes existed over amount recovered and entitlement to statutory 15% collection fees.
Civil procedure – Summary judgment (Order 14) – Requirement of no bona fide defence; Solicitors’ collection fees – statutory 15% under Scales and Minimum Charges (Table 6); entitlement and timing of recovery; necessity of evidence on amount collected and plaintiff’s role; litigant in person claims and bill of costs.
31 December 2003
A respondent's general denial cannot resist summary judgment absent a shown bona fide defence to a conversion and delivery-up claim.
Civil procedure – Summary judgment (Order 14) – General traverse insufficient – Defendant must show cause by affidavit to raise bona fide defence – Conversion/delivery up of vehicle – Change of registration as evidential admission.
31 December 2003
Summary possession under Order 113 inappropriate where ownership and bona fide purchaser issues require plenary proceedings.
Property law – recovery of possession – Order 113 RSC – wrongful occupation vs purchaser with defective title – bona fide purchaser – summary proceedings inappropriate where title disputed – proceed by writ – service of process.
31 December 2003
Damages for conversion and loss of use awarded to the applicant after respondent's agents seized her household goods; costs to applicant.
Property law – Conversion and trespass to goods – Appropriate remedy where goods not returned – Measure of damages for conversion (market value at time of wrong v. value at assessment) – Damages for loss of use of domestic household items – Costs.
31 December 2003
Summary judgment granted where defendant’s uncorroborated assertion of cheque payment failed to disclose a bona fide defence.
Civil procedure – Summary judgment (Order 14) – Defendant must show bona fide defence supported by credible evidence – Mere assertion of cheque payment insufficient – Production of bank statements or equivalent may be required – Non-attendance undermines defence.
31 December 2003
Summary judgment application undermined by material discrepancies between affidavit figures and particulars of claim, failing to prove the debt clearly.
Civil procedure — Summary judgment (Order 14) — Plaintiff must prove debt clearly in affidavit — Inconsistencies between affidavit and pleadings — Omission of payments and unexplained numerical discrepancies defeat summary relief.
31 December 2003
Court continued attachment order where plaintiff sold preserved vehicle in bad faith and ordered consolidation and costs to defendants.
Attachment/preservation orders – ex parte orders and abuse of process – sale of preserved property – bad faith conduct – consolidation of related proceedings – costs awarded.
30 December 2003
Whether a party may withdraw from a fixed-term employment agreement before commencement where the other party’s conduct amounts to anticipatory breach.
Contract law – fixed-term employment agreement – pre-commencement withdrawal – anticipatory breach/repudiatory conduct – objective test – remedies; insufficient evidence for counterclaim.
30 December 2003
Where an injunction already exists, the applicant cannot obtain a second identical injunction; committal is the proper remedy.
Injunctions – ex parte injunctions – consent orders – estoppel – multiplicity of injunctions – remedy for breach of injunction is committal proceedings rather than duplicate injunctions.
28 December 2003
An ex parte injunction enforcing a claimed right of way was retained pending trial because no material suppression was shown.
Civil procedure — interlocutory/ex parte injunction — application to dissolve injunction — suppression of material facts — easement/right of way — prima facie entitlement to easement enforceable by interlocutory relief — factual issues reserved for trial.
28 December 2003
Fine alone inadequate for wildlife trafficking; imprisonment imposed despite statutory ambiguity and first-offender status.
Wildlife law – National Parks and Wildlife Act s.110 – ambiguity in prescribed fine; penal statutes strictly construed; sentencing – first offenders (s.340 Criminal Procedure) – fine versus imprisonment; seriousness and public interest in wildlife trafficking; aggravating conduct (resistance, syndicate activity).
28 December 2003
Interlocutory injunction granted where triable issues and potential loss of goodwill made damages an inadequate remedy.
Contract law – distributorship termination – requirement of written notice and opportunity to be heard – adequacy of damages – interlocutory injunction to preserve goodwill and status quo pending trial.
23 December 2003
Repatriation should be to place of recruitment or nearer home; bank-rate interest and collection-charge orders were unlawful and set aside.
Employment law – repatriation on termination – fair labour practices under constitutional provision – balance of employer and employee interests; Industrial Relations Court jurisdiction – limits on awarding equitable remedies; Award of interest – necessity to plead basis and rate; Legal collection charges – payable by collecting party under Legal Practitioners (Scale and Minimum Charges) (Amendment) Rules 2002; Costs.
21 December 2003
The court held that government funds are immune from garnishee execution; judgments against the State require appropriation/constitutional procedure.
Public law — Immunity from execution — Garnishee proceedings (Orders 45–52) inapplicable to Government — Order 77 r.15 part of domestic practice — section 8 Civil Procedure Act does not authorize common-law execution against State — Constitutional requirement to charge and appropriate Consolidated Fund for judgments.
15 December 2003
Creditor may apply under s.337(1) within existing proceedings; veil lifted for director's scheme to defraud.
Companies Act s.337(1) – lifting corporate veil – application may be made within existing proceedings – no separate originating process required – procedural irregularities curable – intention to defraud shown where director/shareholder sold security offered for company overdraft – failure to file opposing affidavit treated as admission.
11 December 2003
An Assembly may lawfully levy municipal rates during dissolution; equitable ownership and possession render the defendant liable for rates.
Local government law – Power to levy and collect municipal rates during dissolution of assemblies; Rating law – "Owner" for valuation and rating includes equitable owners and those entitled to dispose of an interest; Pleading requirements – specific pleading required for claim for interest; Legal practitioner collection costs – applicable amendment determined by date proceedings commenced.
11 December 2003
No immediate appeal to the Supreme Court lies from a High Court's interlocutory finding that a defendant has a case to answer.
Appeal — interlocutory order — finding of 'case to answer' — final judgment requirement under s.11(1) Supreme Court Act — DPP appeals distinguished — timing of appeal (raise after final judgment).
9 December 2003
High Court may hear "no case" submissions; prosecution evidence here required defendants to enter defence on corrupt-practices charges.
Criminal procedure  Submission of no case to answer; High Court jurisdiction to entertain such submissions; application of Galbraith test. Corrupt Practices Act s24(2)  elements: corruptly give/promise/offer gratification as inducement. Evidence  sufficiency, credibility, and effect of inconsistencies or delay. Amendment of charge under s254(2).
7 December 2003
A receiver appointed to protect an estate is liable for loss from failure to safeguard assets; Section 27 immunity does not cover omissions.
Wills & Inheritance Act – Receiver's duties to take possession and protect estate pending grant – Section 27 immunity not applicable to failure to act; summary judgment under Order 14 appropriate where no bona fide triable defence.
7 December 2003
The applicant successfully set aside a default judgment entered against the wrong party without proper service.
Civil procedure — Default judgment — Irregular judgment where originating process not served on correct legal entity — Misnomer versus amendment — Ex debito justicie relief — Insufficiency of poorly labelled exhibits to prove prior payments.
4 December 2003
Application for bail denied: serious charges, prior flight and confession create absconding risk despite medical complaints and prosecutorial delay.
Bail pending trial – Capital offences (murder) – Exceptional/special circumstances required – Balancing right to liberty against interests of justice – Pre-trial delay and medical illness – Flight risk and confession – Registrar ordered to set down trial.
3 December 2003
November 2003
Court awarded aggravated damages, travel expenses and costs for front-page libel aggravated by imputations of criminality and no apology.
Defamation – libel – assessment of damages – aggravated damages for imputations of criminality – absence of apology or retraction – default judgment and assessment in defendant’s absence – comparative awards and currency depreciation.
30 November 2003
Court awards gratuity, pension, nine years' salary arrears and leave grant for wrongful premature retirement.
Labour law – wrongful premature retirement – assessment of damages – entitlement to gratuity, pension, salary arrears and leave grant – assessment on unchallenged evidence – reliance on MSCA precedent (Chawani v Attorney General).
30 November 2003
Court may revive an action after non-compliance with an unless order where extraneous circumstances justify extension of time.
Civil procedure – 'unless' order – power to revive/delayed compliance – court may extend time to bring action back to life where extraneous circumstances exist – stringent terms and costs may be imposed.
30 November 2003
Ex parte injunction and leave for review discharged: ACB lacks capacity to be sued; non-disclosure and wrong party sued.
:[
28 November 2003
Unpleaded trial evidence of a stationary vehicle cannot be used to establish contributory negligence; defendant held vicariously liable.
Negligence – duty of care – breach causing personal injury; Contributory negligence – requirement that facts supporting the defence be pleaded; Pleadings – admissibility of evidence first raised at trial; Vicarious liability – employer liable for servant's negligence; Remittal for assessment of damages.
21 November 2003
A dismissal under contract can be constitutionally unfair if the employer fails to give reasons and an adequate opportunity to answer allegations.
Constitutional law – right to fair labour practices (s31) – natural justice in employment – duty to give reasons and opportunity to answer for misconduct; International law – ILO Termination of Employment Convention binding domestically (pre‑1994 ratification); Remedies – s46 remedies including compensation and reinstatement; Pre‑Employment Act protection for procedural fairness in dismissals.
20 November 2003
Pre-Employment Act dismissal can violate the constitutional right to fair labour practice, warranting discretionary compensatory awards rather than common-law damages.
Constitutional right to fair labour practice (s31) – unfair dismissal before Employment Act – compensation as primary remedy – heads of compensation: immediate wages, manner of dismissal, future loss, loss of severance/benefits – political discrimination as unfair labour practice.
20 November 2003
Termination under contract can be unfair if employer fails to provide investigatory procedure and procedural fairness.
Employment law – wrongful/unfair dismissal – contractual termination vs procedural fairness – natural justice applies where termination is for conduct – Constitution s.31 fair labour practice – Employment Act s.57 – Termination of Employment Convention – damages awarded: one month’s salary per year of service.
20 November 2003
Whether the applicant’s transfer was a secondment retaining employment for redundancy-pay calculation, including Kenyan salary.
Employment law – transfer/secondment within corporate group – whether transfer terminated original contract – redundancy pay calculation – inclusion of foreign salary and allowances – enforceability of agreed redundancy arrangements – effect of "full and final" receipt signed under pressure.
20 November 2003
October 2003
A defendant may set aside a default injunction judgment by showing a meritorious defence and that the plaintiff lacks clean hands.
Civil procedure – setting aside default judgment (Order 19 r 9) – defendant must show bona fide defence on the merits (Farden v Richter) – equitable relief and clean hands doctrine – dispensing with service of defence – costs where judgment regularly entered.
31 October 2003
Confession held admissible; false accounting on delivery note not forgery; theft proven in part, defendant released immediately.
Criminal law – admissibility of confession – voluntariness and unrepresented accused; Forgery – definition and limits; False accounting versus forgery; Theft by servant – requirement to prove quantum of property stolen for conviction and sentencing.
29 October 2003
Interlocutory injunction refused where damages are adequate and plaintiff cannot show ability to meet undertaking as to damages.
Interlocutory injunction — adequacy of damages — American Cyanamid principles — undertaking as to damages — agency and alleged fraud reserved for trial.
29 October 2003
A summary judgment applicant cannot routinely cross‑examine a company officer on an adopted affidavit; leave is exceptional.
Civil procedure — Summary judgment (Order 14/Part 24 CPR) — Cross‑examination of affidavit deponents — Company officer adopting another affidavit — Leave to cross‑examine exceptional — Fraud allegations more appropriately resolved at trial.
28 October 2003
Application to dissolve ex parte interlocutory injunction dismissed; injunction maintained pending administration and distribution of the estate.
Civil procedure – interlocutory (ex parte) injunction – dissolution application – material non‑disclosure – adequacy of damages – balance of convenience/status quo pending appointment of administrator.
28 October 2003
Whether the applicant solicitors may compel the defendants to pay solicitor‑client collection fees directly under amended scale rules.
Solicitor's lien; direct payment to solicitor; taxation of costs; Legal Practitioners (Scale and Minimum Charges) (Amendment) Rules 1999; statutory notice under Civil Procedure (Suits by and Against Government) Act; stay for arbitration; indemnity principle.
22 October 2003
Plaintiff had standing; amendment invalid insofar as it extended floor‑crossing to parties/associations outside Parliament.
Constitutional law — locus standi under sections 15(2) and 46(2) — judicial review of constitutional amendments — crossing the floor — limits on freedom of association and political rights — severance of unconstitutional portions of an amendment.
5 October 2003
Appellate court increased burglary sentences by two years each due to multiple offenders, absence of guilty pleas, and prior convictions.
Criminal law — Sentencing — Burglary — Starting point six years' imprisonment — Appellate enhancement for aggravating factors (multiple offenders, no guilty plea, prior convictions) — Review of sentence disparity.
2 October 2003
Court reduced a manifestly excessive six-year burglary sentence to four years after balancing aggravating factors and mitigation.
Criminal law – Sentencing – Burglary/housebreaking – Aggravating factors (violence, damage, multiple offenders, vulnerable victims) – Mitigating factors (youth, first offender, guilty plea, cooperation) – Chizumila six-year threshold – Simple burglary minimum three years.
2 October 2003
Conviction upheld despite defective particulars where no prejudice; burglary sentence deemed manifestly inadequate but not increased as already served.
Criminal procedure – Duplicity in charge – section 128 requirements – particulars of offence; Plea of guilty – prejudice test for defective charge; Sentencing – burglary/housebreaking – Chizumila six-year threshold; Simple burglary minimum three years; Review of sentence after sentence served.
2 October 2003
Court reduces an excessive burglary sentence to three years, applying factors like youth, guilty plea and victim vulnerability.
Criminal law – Sentencing – Burglary/housebreaking – sentencing factors (actus reus and mens rea, offender's age, first offender, guilty plea, victim vulnerability) – Chizumila starting point and threshold burglary – simple burglary minimum custodial sentence three years.
2 October 2003
Whether duplicative particulars vitiate conviction and whether a twelve‑month burglary sentence was manifestly inadequate.
Criminal law – Charge drafting – duplicity in particulars – s.128 Criminal Procedure and Evidence Code – guilty plea – conviction confirmed where defect caused no prejudice; Sentencing – burglary/housebreaking – Chizumila starting point (six years) and minimum three years for simple burglary; factors: victim vulnerability, multiple offenders, plea and antecedents; late review after sentence served.
2 October 2003