High Court of Malawi - 2015

56 judgments
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Results. 56 judgments found.

56 judgments
December 2015
Appellate court declines to disturb magistrate’s fair distribution of matrimonial property; appeal dismissed.
  • Family law — Matrimonial property — Division of assets — Appeal by rehearing — Appellate interference with magistrate’s factual and discretionary distribution of matrimonial property.
21 December 2015
Property acquired during a customary marriage is family property; indirect contributions justify equitable distribution.
  • Matrimonial property distribution — Customary marriage — Recognition of direct and indirect contributions (domestic labour and assistance in family enterprises) — Family estate not matrimonial property — Application of constitutional protections (s.22, s.24(1)).
21 December 2015
The applicant's claims of illegal distress, seizure and eviction dismissed for failure to prove wrongful seizure or illegality.
  • Land law
    • — Distress for rent — Warrant of distress not essential though advisable — Authority of sheriff/bailiff and notice of distress govern validity
    • — Eviction — Sealing premises and handing keys to landlord constitutes eviction and may be ratified by landlord
  • Tort — Trespass and conversion — Claimant must prove seizure of non-distrainable items; failure to call material witnesses and absence from inventory undermines claim
17 December 2015
Reapplying for bail in the trial court while appealing its revocation constitutes abuse of process; application dismissed.
  • Criminal procedure — Bail
    • — Restoration of bail after revocation — Concurrent application in trial court and pending appeal may constitute abuse of process
    • — Change of circumstances — Alleged medical deterioration must be substantiated to justify restoration of bail
  • Criminal procedure — Applicability of CP&EC s 3 and s 5 — Not engaged where no error or procedural irregularity on the record is shown
17 December 2015
Unopposed, measured affidavits of encroachment entitle the plaintiff to relief for trespass and costs.
  • Land law — Trespass (tort) — Encroachment established by unopposed affidavits — Relief and costs
15 December 2015
Assessment of damages for plaintiff bitten by defendant's dogs; court awarded K7,000,000 plus costs.
  • Personal injury — assessment of damages — dog-bite injuries — pain and suffering; loss of amenities of life; disfigurement — use of comparative awards to fix quantum.
14 December 2015
Long delay and failure to pay revaluation fees amounted to repudiation; seller entitled to rescind and claimant’s reliefs denied.
  • Contract law — Sale of land — Whether time is of the essence and when notice is required to make time of the essence
  • Equity — Specific performance & laches — Readiness and willingness to perform and long delay as bar to equitable relief
  • Registered land — Vendor’s lien and overriding interests — Effect of registration on seller’s equitable rights under Registered Land Act
14 December 2015
High Court dismissed IRC appeal for failing to raise any question of law or jurisdiction under section 65(2) LRA.
  • Labour law — Appeal from Industrial Relations Court — s.65(2) Labour Relations Act — appeal limited to questions of law or jurisdiction — High Court will not re-appraise factual findings or admit new issues on appeal — pension fund transfer dispute.
7 December 2015
Interlocutory injunction refused for lack of a triable claim; leave granted to correct the defendant's corporate name.
  • Civil procedure
    • — Interlocutory injunction — Application of American Cyanamid principles — Requirement of a good arguable/triable claim
    • — Amendment of pleadings — Misnamed defendant — Leave to amend where no prejudice suffered
  • Contract law — Alleged delay in disbursement — Need to identify and prove breach under the correct agreement
4 December 2015
November 2015
Delay in utility connection not a contractual breach where notice of possible delays existed and time was not of the essence.
  • Contract law
    • — Time for performance — Whether time was of the essence where written notice warned of possible delays
    • — Remedies for breach — Reasonable time, causation and foreseeability of consequential losses
29 November 2015
Whether distinct injuries from one accident must be aggregated under section 9 of the Workers Compensation Act.
  • Workers Compensation Act — Aggregation of multiple injuries — Section 9 — Compensation by aggregated percentages not exceeding 100%
  • Civil procedure — Appeal and referral under Workers Compensation Act — Role of Commissioner, magistrate and High Court; functus officio status of Commissioner
  • Medical assessment — First Schedule entries — Requirement to catalogue and percentage-assess all distinct injuries
26 November 2015
Applicant’s bank payment unproven; lawful statutory disconnection not trespass or defamation, claim dismissed.
  • Tort
    • — Trespass to land — Entry by utility under statutory power to disconnect service — Authority and licence to enter
    • — Defamation — Justification (truth) as defence where conduct reflects unpaid arrears
  • Contract/Payment — Payment via bank does not discharge debtor’s obligation absent agreement or proof of credit to creditor’s account
26 November 2015
Claimant failed to prove contamination occurred under manufacturer's control; claim dismissed for lack of causation evidence.
  • Tort
    • — Negligence — Manufacturer’s duty to ultimate consumer — Liability only where defect existed while product under manufacturer’s control
    • — Causation — Onus on claimant to prove absence of intervening acts; evidence of sealed container critical to infer defect at manufacture
  • Civil procedure — Joinder of parties — Proper basis required to join insurer where contractual privity not pleaded
25 November 2015
Decree nisi granted where petitioner proved respondent's serial adultery; jurisdiction established and costs awarded.
  • Family law — Divorce — Jurisdiction (domicile) under s.2 Divorce Act — Adultery as ground for divorce — Undefended petition and unchallenged evidence — Decree nisi and costs awarded.
16 November 2015
Court corrected its omission and held the respondent entitled to compound interest at the contractual rate, dismissing the applicant's simple-interest request.
  • Civil procedure — correction of clerical mistake (Order 20 rule 11) — Interest — contractual rate (2% above prime or maximum permitted) — simple versus compound interest — commercial transactions; compound interest recoverable where contract silent.
2 November 2015
October 2015
Chief Justice recused from certifying constitutional referral due to perceived bias and ceded authority via inherent jurisdiction.
  • Constitutional law — Certification of constitutional matter — Whether Chief Justice may certify where prior judicial involvement creates apprehension of bias — Courts Act s 9(2)–(3)
  • Judicial conduct — Recusal and perceived bias — Test for reasonable apprehension of bias and application where judge chaired related inquiry
  • Civil/constitutional procedure — Inherent jurisdiction — Use to cede authority to another judge in the interests of justice to prevent denial of remedy
28 October 2015
26 October 2015
Registration presumption of vehicle ownership was rebutted by uncontradicted transfer evidence, making the purchaser liable in tort.
  • Road traffic — Vehicle ownership — Registration raises rebuttable presumption of ownership — Road Traffic Act ss 2, 136(1), 139(1)
  • Evidence — Rebutting presumption — Uncontradicted corporate witness testimony and transfer document sufficient; hearsay inadmissible for subsequent sale
  • Civil procedure — Third‑party proceedings — Failure to respond to third‑party notice and cost/indemnity consequences — Order 16 Rules of Supreme Court
13 October 2015
In a Chitengwa marriage, property registered in one name can be jointly held and, absent special circumstances, must be equally divided under constitutional fairness.
  • Family law — Matrimonial property
    • — Customary marriage — Application of section 24(1)(b)(i) fairness principle to property 'held jointly'
    • — Registered title and alleged gift — Registration or gifting does not conclusively negate joint holding under customary law and the Constitution
  • Family law — Maintenance and property division — Interaction of section 24(1)(b)(ii) fair maintenance with equal sharing and burden to prove maintenance needs
7 October 2015
Whether the respondent’s report amounted to laying a charge, giving rise to false imprisonment and defamation, but not malicious prosecution.
  • False imprisonment — distinction between reporting a crime and laying a charge; Defamation — false statement, publication and reputational injury; Malicious prosecution — requirement of procuring/procurement, absence of malice and probable cause; Civil burden of proof — balance of probabilities.
7 October 2015
September 2015
Appeals to the High Court from the Industrial Relations Court are limited to questions of law or jurisdiction; factual appeals are not permitted.
  • Labour Relations Act s65 — Appeals from Industrial Relations Court to High Court limited to questions of law or jurisdiction; findings of fact final; factual appeals dismissed.
4 September 2015
Court imposed 11 years’ imprisonment (consecutive) for massive money laundering and conspiracy despite plea, cooperation and restitution.
  • Economic crimes — Money laundering and conspiracy to defraud — Large-scale public fund embezzlement — Weight of guilty plea, cooperation and restitution in mitigation — Consecutive versus concurrent sentences — Sentencing triad: culpability, offender circumstances, public interest.
4 September 2015
A consent order prescribing an agreed manner of tax payment binds the tax authority; a retrospective lien without statutory basis is unlawful.
  • Civil procedure — Consent orders binding and estoppel; Tax law — creation and effect of tax liens (Taxation Act s.107A); Lien requires neglect/refusal to pay and statutory filing; Commissioner’s discretion to accept alternative payment arrangements.
1 September 2015
High Court may only hear Industrial Relations Court appeals on questions of law or jurisdiction; factual appeals are dismissed.
  • Labour Relations Act s65(2) — appeals from Industrial Relations Court limited to questions of law or jurisdiction — factual and evidential findings by Industrial Relations Court final and binding — High Court may not re-examine internal disciplinary procedure or factual determinations.
1 September 2015
August 2015
Immediate termination was unfair where the defendant failed to prove fundamental non‑performance by the contractually required reports.
  • Contract — Termination for breach — Immediate termination under clause 19.1 — Termination must be founded on breach going to the root of the contract and be fair — Proof by contractually-prescribed weekly/completed field weeding reports
  • Evidence — Documentary proof and hearsay — Daily labour statistics and unverified photographs insufficient to establish contractual non‑performance
  • Contract law — Implied terms — No general implied duty of good faith in all commercial contracts under Malawian law
30 August 2015
High Court set aside magistrate’s estate distribution for lack of jurisdiction and appointed the Administrator General to administer the estate.
  • Deceased estates — Jurisdiction of subordinate courts limited to 'small estates' (≤ K1,000,000) — Magistrate exceeded jurisdiction by distributing larger estate; jurisdiction can be raised on appeal; Administrator General appointed as receiver of letters of administration under s23.
28 August 2015
The appellant's theft-by-servant conviction was set aside for unsafe reliance on stock shortages and defective charging.
  • Criminal law — theft by servant — stock shortages — circumstantial evidence — exclusive control and access — alternative explanations — illicit enrichment requirement — inadmissible hearsay — defective omnibus charging.
20 August 2015
Sentencing may proceed while confiscation/penalty applications are postponed, but confiscation (in rem) and pecuniary penalties (in personam) are treated differently and procedural safeguards apply.
  • Money laundering — MLA: confiscation order is in rem against tainted property; pecuniary penalty/payment-in-lieu is in personam and punitive; Section 51(2) permits deferral of confiscation/penalty proceedings; sentencing and confiscation largely separate but procedural safeguards required when proceedings are postponed; disclosure order for bank cheque images.
3 August 2015
July 2015
The respondent unlawfully declared the applicants' strike illegal and withheld pay; those decisions were ultra vires and invalid.
  • Labour law — Right to strike — Declaration of illegality — Jurisdiction for declaring illegality vested in Industrial Relations Court or High Court
  • Administrative law — Judicial review — Ultra vires act and denial of audi alteram partem — Withholding wages as disciplinary/administrative action requiring hearing
27 July 2015
Applicant lacked standing to challenge regulator’s re‑opening of licence negotiations due to operational incapacity to compete.
  • Administrative law — Judicial review — Standing/sufficient interest — Whether an applicant dependent on another operator’s network has sufficient interest to challenge regulator’s licence decision — Order 53 r 3(7)
  • Telecommunications law — Licensing — Individual versus general licence — Whether call‑back/voice telephony requires an individual licence under s 18(3)(a) Communications Act
23 July 2015
Court refused to strike out the defence, ordering defendants to amend inconsistent pleadings rather than dismissing them.
  • Civil procedure — Order 18 r.19 (strike out/amend pleadings) — discretionary power sparingly exercised — triable issues (contributory negligence) preclude striking out; inconsistent/embarrassing pleadings to be amended; Order 2 r.1 curative power.
13 July 2015
Magistrate court lacked jurisdiction over leased farm land; judgment set aside and land vested in appellant pending High Court proceedings.
  • Civil procedure — Jurisdiction — Subordinate magistrate courts — Section 39(2)(a) Courts Act — Land comprising a leased farm — Proceedings void for lack of jurisdiction — Judgment set aside; interim vesting of land in appellant pending High Court determination.
2 July 2015
June 2015
A two-month delay in seeking to set aside a default judgment was held inordinate; merits did not justify relief.
  • Civil procedure — setting aside default judgment — promptness and reasonable time; merits of defence insufficient where delay is inordinate; two-month delay held inexcusable.
15 June 2015
15 June 2015
Whether assisting police with information constitutes false imprisonment or malicious prosecution where arrest was based on reasonable suspicion.
  • Tort
    • — False imprisonment — Liability for supplying information or assisting police — Whether assistance equates to laying a charge — Penal Code s 328
    • — Malicious prosecution — Elements (initiation by defendant; termination in favour; absence of reasonable and probable cause; malice) — Assistance to police does not itself establish malice or lack of probable cause
9 June 2015
Whether plaintiffs proved that a negligent overtaking caused a bus to overturn and whether the driver’s conviction was admissible.
  • Road traffic — Negligence — Overtaking causing accident — Burden of proof and witness credibility
  • Evidence
    • — Previous criminal conviction — Admissibility in civil proceedings — Hollingworth rule applies
    • — Failure to call material witness and conflicting eyewitness accounts — Inference and weight
1 June 2015
May 2015
A missing trial record does not bar sentence re-hearing; death sentence inappropriate where material circumstances remain uncertain.
  • Homicide sentence re-hearing — Missing or destroyed trial record — Court may proceed to re-sentence; s.260 CP&EC permits receiving external evidence to inform sentence — Cannot challenge conviction on re-hearing — Death sentence inappropriate where material circumstances uncertain — Youth, first offender status and time served as mitigating factors.
31 May 2015
Court varied property award to recognise non-financial contributions, upheld instalment payment for village house, and maintained children’s maintenance order.
  • Family law — Divorce and ancillary orders — Fair distribution of matrimonial property — recognition of non-financial contributions; maintenance orders — assessment by reference to payer’s means and children’s best interests; instalment payments justified where payer lacks means; appellate review limited without fresh evidence.
20 May 2015
8 May 2015
April 2015
Leave for judicial review refused because statutory High Court review is an adequate alternative remedy, interpreted compatibly with the right to counsel.
  • Judicial review — Wednesbury unreasonableness — alleged bias — statutory review/supervision under CP & EC and Courts Act — constitutional right to legal representation — interpretation of statutory exclusion of hearing rights.
30 April 2015
On resentencing after mandatory death invalidation, the applicant's post‑conviction rehabilitation justified a 20‑year term.
  • Homicide — sentence rehearing after mandatory death invalidation — admissibility of expert declaration — relevance of post‑conviction rehabilitation on resentencing — mitigating factors and 'rarest of the rare' death‑penalty threshold.
23 April 2015
Trial held in prison without Chief Justice direction is a nullity; confessions obtained by compulsion must be excluded.
  • Constitutional law — appeal or review under section 42(2)(e) — statutory expansion of rights; Criminal procedure — venue — trials in prison precincts without Chief Justice direction violate public hearing right; Evidence — confessions — section 176 CPE Code admits only relevant and admissible confessions; confessions obtained by compulsion/torture (sections 19(3), 42(2)(c)) must be excluded; procedural requirement that courts determine voluntariness as preliminary factual matter; date in charge generally not essential.
21 April 2015
Court finds the accused malingering, admits psychiatric reports, and determines the accused is mentally fit to stand trial.
  • Criminal procedure — Fitness to stand trial — Court is the trier of fitness; psychiatric experts render opinion — Section 133 CP&EC — Malingering and presumption of mental capacity.
16 April 2015
14 April 2015
Court referred constitutional challenge to rule banning probate proceedings in district registries to Chief Justice for certification.
  • Constitutional law — Rule 2(2) Courts (High Court) (Procedure in District Registries) Rules — probate jurisdiction — district registries barred from issuing originating probate process; issues raised: access to justice (s.41(2)), effective remedy (s.41(3)), right to development (s.30), equality (s.20), High Court jurisdiction (s.108(1)), and consistency with Deceased Estates Act read with s.10(2) Constitution — referral to Chief Justice for certification under Courts Act.
9 April 2015
March 2015
Appeal affirmed on conviction for defilement; ten‑year sentence reduced to eight years for first offender of advanced age.
  • Criminal law
    • — Sexual offences — Defilement of girl under 16 — Corroboration of unsworn child evidence — Proof beyond reasonable doubt
    • — Sentencing — First offender and advanced age — Reduction of sentence — Criminal Procedure and Evidence Code s 340(1)
29 March 2015
Whether a trustee can validly encumber trust land without co‑trustee consent and whether originating summons is appropriate.
  • Registered Land Act ss 60(1) & 96(1)(a) — trustee’s power to create charges; validity of surety charge without co‑trustee consent; rectification of land register for mistake or fraud; appropriateness of originating summons where core facts and credibility are contested.
26 March 2015
Court granted instalment payments, stressing full disclosure and cautious exercise of discretion in judgment-debt applications.
  • Payment of judgment-debt by instalments; discretion; full, frank and honest disclosure; balancing creditor's right to immediate recovery and debtor's inability; trading debts; statutory interest 5% p.a.
24 March 2015
Whether legality of a strike and related wage deductions are amenable to judicial review or fall within private employment law.
  • Administrative law — Judicial review — Amenability of decisions on strike legality and wage deductions to judicial review
  • Labour law — Industrial relations — Jurisdiction to declare a strike illegal and appropriate forum (High Court vs Industrial Relations Court)
  • Civil procedure — Leave to apply for judicial review — Discharge of leave only where substantive application will clearly fail
2 March 2015
February 2015
27 February 2015