High Court of Malawi - 2003 October

17 judgments

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17 judgments
Citation
Judgment date
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
False accounting in delivery notes does not amount to forgery; confession admissible but full amount of theft not proved.
Criminal law – admissibility of confession where accused alleges police force; forgery vs false accounting – false entries in company documents do not necessarily constitute forgery; theft by servant – requirement to prove amount stolen for sentencing
29 October 2003
Interlocutory injunction refused because damages were adequate and plaintiff failed to show inability to pay.
Interlocutory injunction — American Cyanamid principles — adequacy of damages — undertaking as to damages — disputed agency and fraud — balance of convenience
29 October 2003
Cross-examination of a company's affidavit deponent in summary judgment is exceptional and inappropriate where fraud allegations warrant a trial.
Civil procedure – Summary judgment (Order 14/Part 24) – Cross-examination of affidavit deponent – Company officer adopting another affidavit – Leave to cross-examine should be rare and limited – Serious allegations of fraud require trial, not summary oral examination
28 October 2003
Court refused to dissolve ex parte injunction against sale of intestate estate, finding non-disclosure immaterial and balance of convenience favored maintenance.
Civil procedure — Interlocutory (ex parte) injunction — Non‑disclosure materiality — Application of American Cyanamid principles — Intestate estate — Sale by beneficiary without letters of administration — Balance of convenience and preservation of status quo
28 October 2003
Court refused to order defendants to pay plaintiffs solicitors directly; upheld judgment for costs, criticized 1999 rules altering indemnity principle.
Civil procedure - judgment in default for liquidated sum; government suits - section 4 notice not required for contractual claims; arbitration - discretion to stay only where appropriate; solicitors lien - no order to compel defendant to pay solicitor directly except in exceptional equitable cases; costs law - Legal Practitioners (Scale and Minimum Charges) (Amendment) 1999 alters indemnity principle, 15% collection charge recoverable as part of judgment but subject to taxation
22 October 2003
Whether the applicant has standing and whether the expanded ‘crossing the floor’ amendment infringes association and political rights.
Constitutional law — standing — Sections 15(2) and 46(2): broad purposive locus standi for persons/groups protecting rights; constitutional amendment — Section 65(1) (crossing the floor): limits on freedom of association (s.32) and political rights (s.40); referendum requirement — Sections 196/197 and schedule; severance of unconstitutional portions under Sections 5 and 11(3) and jurisdiction s.108(2)
5 October 2003
On review the court enhanced burglary sentences, finding a six-year starting point and prevailing aggravating factors.
Criminal law – Burglary – Sentencing – High Court starting point six years – Aggravating factors (multiple offenders, no guilty plea, prior convictions) – Disparity in sentences – Sentences enhanced on review
2 October 2003
A six-year burglary sentence was reduced to four years after balancing aggravating and mitigating factors.
Criminal law – Sentencing – Burglary/housebreaking – sentencing principles and factors – Chizumila six-year starting point; three-year minimum for simple burglary – aggravating factors (violence, vulnerable victim) v. mitigating factors (youth, first offender, guilty plea, cooperation) – review and reduction of manifestly excessive sentence
2 October 2003
Conviction upheld despite duplicity in the charge where no prejudice existed; burglary sentence found manifestly inadequate but already served.
Criminal procedure – Duplicity in charge/particulars contrary to section 128 – No prejudice vitiating conviction; Sentencing – burglary/housebreaking: Chizumila starting point six years, simple burglary minimum three years; factors: vulnerability of victims, multiple participants, guilty plea, first offender status; late review after sentences served
2 October 2003
Sentencing for burglary must balance offence seriousness, offender mitigation and victim vulnerability; simple burglary attracts a minimum three-year custodial term.
Criminal law – Sentencing – Burglary/housebreaking – sentencing principles; actus reus and mens rea factors; starting/threshold sentence (Chizumila) – simple burglary minimum three years – mitigation: youth, first offender, guilty plea; victim vulnerability as aggravation
2 October 2003
Whether duplicity in the charge prejudiced the accused and whether the burglary sentence was manifestly inadequate.
Criminal procedure – Duplicity in charge and section 128 – convictions may be confirmed where defective particulars occasion no prejudice; Sentencing – burglary/housebreaking: sentencing principles, Chizumila starting point (six years), minimum for simple burglary (three years); manifestly inadequate sentence
2 October 2003
Six-year burglary sentence reduced to three years; courts must prove or put prior convictions to defendant before relying on them.
Criminal law – Sentencing principles for burglary/housebreaking – balancing actus reus, mens rea, offender and victim circumstances – previous convictions must be proved or put to defendant before reliance – simple burglary minimum custodial sentence three years
2 October 2003
Conviction sustained despite defective plea; sentencing principles for burglary affirmed and inadequate sentence confirmed due to time served.
Criminal law – Plea procedure – Defective plea curable under section 5 where no failure of justice; Criminal law – Sentencing – burglary/housebreaking; Chizumila six-year starting point and three-year minimum for simple burglary; sentencing factors (actus reus, mens rea, offender’s age, antecedents, remorse, victim vulnerability); confirmation of sentence where already served
2 October 2003
Sentencing for burglary must account for victim vulnerability and disturbance; excessive concurrent sentences were reduced.
Criminal law — Sentencing — Burglary/housebreaking — Chizumila six-year starting point — Factors: victim vulnerability, disturbance, offender’s age/first offender status, plea — Concurrent sentences; manifestly excessive sentence reduced
2 October 2003
Whether a six-year burglary sentence was excessive given a young first offender and a simple, non-violent trespass.
Criminal law – Sentencing – Burglary – Sentencing factors: nature of offence, offender’s antecedents, victim’s vulnerability, public interest – Six-year threshold for serious burglary; simple burglary minimum three years
2 October 2003
Court quantified damages for two children’s deaths and plaintiff’s injuries using multiplier method; unpleaded loss of earnings refused.
Damages assessment – death of children – loss of expectation of life and loss of dependency for minors – use of half average industrial earnings and multiplier method – unpleaded heads of damage not recoverable – awards for funeral and medical incidentals following default judgment
1 October 2003