High Court of Malawi - 2017

281 judgments

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281 judgments
Citation
Judgment date
December 2017
Plaintiff awarded MK3,000,000 for loss of use of title deed; special damages not proven.
Assessment of damages – wrongful retention of title deed – loss of use as general damages – distinction between general and special damages – requirement of strict proof for special damages – restitution in integrum – nominal damages where amount not proved.
22 December 2017
Stay of damages assessment pending appeal denied where appellant failed to show risk of injustice or inability to repay.
Civil procedure — Stay of proceedings pending appeal — Interlocutory judgment and assessment of damages — Discretion to grant stay guided by risk of injustice — Stay of execution vs stay of proceedings — Prematurity of application.
20 December 2017
Court refused the applicant’s stay pending appeal as premature and unjustly prejudicial to the respondent.
Stay pending appeal – discretionary exercise – consider risk of injustice and prejudice; Interlocutory judgment – liability final but damages to be assessed; Applicant’s burden to show special circumstances and inability of respondent to repay; Prematurity of application to stay assessment of damages; Appropriate remedy may be stay of execution after Registrar’s assessment.
20 December 2017
18 December 2017
18 December 2017
18 December 2017
Arson conviction confirmed; 84‑month sentence set aside as manifestly excessive and reduced to effect immediate release.
Criminal law — Arson — Sentence on review — Manifestly excessive sentence reduced on account of guilty plea and first offender status — Magistrates’ Court Sentencing Guidelines and section 337(A) considered — Court may vary sentence on review even when parties absent.
18 December 2017
Leave to seek judicial review refused where impugned acts were recommendations and the wrong public officer was sued.
Administrative law – Judicial review – Leave to apply requires an arguable case – Ripeness: recommendations by inspectors v. final decisions – Proper party: only the public office/officer who made the impugned decision is liable – TEVETA Board decisions.
13 December 2017
Excessive 17-year pre-trial detention constituted gross injustice justifying immediate release despite a 12-year manslaughter sentence prospect.
Criminal law – Manslaughter – Conviction on plea of guilty – Sentence – Mitigating factors: guilty plea, youth, first offender, intoxication, remorse – Aggravating factors: use of knife, multiple fatal wounds – Inordinate pre-trial detention (17 years) as ground for release.
12 December 2017
Summary judgment granted where defendant’s general denial lacked particulars; estate/dependants claims refused for lack of letters of administration.
Civil procedure — Summary judgment (Order 14 RSC) — General denial without particulars is not a bona fide defence — Legal capacity to sue for estate and dependants — Letters of administration required.
11 December 2017
Court exercised discretion to fix taxation rate (K10,000/hr), excluded prior appellate/Registrar-awarded costs, and allowed defendant set-off at K5,000/hr.
Civil procedure — Taxation of party-and-party costs — Court’s discretion to fix hourly rates — Prior Registrar’s rate revision held invalid — Expense rate fixed at K10,000/hour — Prior appellate and Registrar cost orders given effect — Leave to tax out of time and set-off at K5,000/hour.
11 December 2017
Bank negligent in delayed action and CCTV management; customer also contributorily negligent; second appellant’s claims dismissed.
Bank negligence – failure to block account and preserve CCTV evidence – contributory negligence apportionment between bank and customer; civil claims of false imprisonment, malicious prosecution and defamation require proof of improper conduct or malice by the claimant.
11 December 2017
Summary judgment granted where defendants offered only general denials and insurer’s payments supported liability.
Civil procedure – Summary judgment (Order 14 RSC) – Plaintiff’s burden to establish claim – Defendant’s duty to plead particularized bona fide defence – General denials insufficient – Insurer’s payments to third-party claimants as evidence of indemnity/liability.
8 December 2017
Judicial review inappropriate to challenge adequacy of compensation; administrative process was fair and eviction upheld.
Administrative law — judicial review limited to decision-making process; adequacy of compensation is a merits issue for ordinary suit; procedural fairness and Wednesbury unreasonableness not established; entitlement to adequate notice and compensation satisfied.
6 December 2017
Court upheld convictions for malicious damage and theft based on circumstantial evidence, partially reducing the sentence.
Criminal law – Malicious damage and theft – Circumstantial evidence and direct identification – Malice includes intention and recklessness – Defective charge requires prejudice to set aside conviction – Sentencing: role of offender, aggravating factors, and concurrent sentences; reduction where excessive.
6 December 2017
Application for stay of execution dismissed where defendant negotiated directly with a represented plaintiff despite a valid default judgment.
Civil procedure – stay of execution (Order 10 Rule 5) – effect of out-of-court settlement/payment made directly to a represented party – default judgment regularly obtained – abuse of process where defendant negotiates behind plaintiff's counsel.
1 December 2017
The 2nd applicant, an innocent purchaser for value without notice, obtains ownership; respondent entitled only to judgment balance.
Registered Land Act; Statute of Frauds; sale of land; bona fide purchaser for value without notice; effect of prior default judgment on subsequent sale; estate agent involvement in land sale.
1 December 2017
1 December 2017
November 2017
Employer may deduct from wages for restitution but cannot withhold employees' pension to recover debts.
Employment law – recovery of employer losses – s56(4) Employment Act: deductions from wages permissible; Pension law – pension benefits not attachable to settle employee debts; remedies for seized property.
30 November 2017
Applicant on prolonged remand granted bail with strict conditions including cash bond, sureties, reporting, and surrender of travel documents.
Criminal procedure – Bail – Applicant on prolonged remand granted bail – State non-objection but requests strict conditions – Conditions imposed: cash deposit, two bonded sureties, periodic police reporting, travel restrictions, surrender of travel documents, examination of sureties before Registrar.
30 November 2017
Bail granted despite overstay on remand, subject to strict conditions to ensure attendance and protect the administration of justice.
Bail — Grant of bail where accused has overstayed on remand — Interest of justice — Imposition of conditions: cash deposit, sureties, periodic police reporting, surrender of travel documents — Examination of sureties before Registrar.
30 November 2017
Applicant granted bail pending trial with strict cash, surety, reporting and travel-document surrender conditions.
Criminal procedure – Bail application – Overstay on remand – Bail Guidelines Act s12; Criminal Procedure and Evidence Code s118; Constitution s42(2)(e) – Conditions of bail: cash deposit, bonded sureties, reporting requirements, travel-document surrender, examination of sureties.
30 November 2017
Summary judgment granted where insurer's general denial and unsupported contributory-neglect plea failed to constitute a bona fide defence.
Civil procedure – Summary judgment (Order 14 RSC) – Defendant must file an affidavit with particulars – Bare denials and unsupported contributory negligence plea are not bona fide defences – Insurer’s vicarious liability where insurer not disputed – Sham defence doctrine.
29 November 2017
Summary judgment granted where defendant's general denial lacked particularized facts to raise a bona fide defence in a negligence claim.
Civil procedure – summary judgment (Order 14 RSC) – requirement for a defendant to raise a bona fide defence with particularized facts – negligence/personal injury – general denials insufficient to defeat summary judgment.
28 November 2017
Summary judgment refused where defendant’s denial of insurer status and plea of contributory negligence raised bona fide triable issues.
Civil procedure — Summary judgment (Order 14 RSC) — Exceptional remedy — Bona fide defence and triable issues — Contributory negligence — Denial of insurer status — Admissibility/weight of affidavit sworn by counsel — Liability to be determined at trial.
21 November 2017
Court dismissed the action for want of prosecution due to inordinate delay, granting liberty to restore within 30 days.
Civil procedure — dismissal for want of prosecution — High Court Civil Procedure Rules 2017 — active case management (Order 1 r.5) — inordinate and inexcusable delay — liberty to restore — costs awarded.
20 November 2017
An Order 14A application was dismissed because disputed adverse possession and notice issues require a full trial.
Civil procedure — Order 14A RSC — Summary determination inappropriate where issues of adverse possession, bona fide purchaser status and limitation raise factual disputes requiring full trial and cross‑examination; prior judicial directions to proceed to trial preclude pre‑emptive interlocutory determination.
17 November 2017
Insurer struck out because the policy excluded passenger cover and the plaintiff had no cause of action against it.
Insurance law – insurer struck out where policy expressly excluded passenger cover; Road Traffic Act s.144 does not universally mandate passenger insurance; sanctity of contract; Order 15 r.6(2) RSC – striking out improperly joined parties.
16 November 2017
Trial held in chambers without sufficient reasons breaches right to public trial; proceedings declared nullity and retrial ordered.
Constitutional right to public trial — s42(2)(i); Criminal Procedure & Evidence Code s71; Courts Act s60 — in camera exceptions require sufficient reasons; trials in chambers/prisons without Chief Justice designation invalid; remedy: proceedings declared nullity and retrial ordered.
14 November 2017
Court awarded the plaintiff K3,806,000 for pain, loss of amenities, disfigurement and report costs after a vehicle collision.
Tort – assessment of non-pecuniary damages – pain and suffering; loss of amenities of life; disfigurement – reliance on comparable cases and adjustment for currency devaluation – award of documentary costs.
9 November 2017
Prosecution discontinuance resulted in the accused’s discharge under s77 and discharge of bail and recognizances.
Criminal procedure – Discontinuance by prosecution – Discharge under s 77 Criminal Procedure and Evidence Code – Effect on bail and recognizances.
8 November 2017
Summary disposal inappropriate where consultations in redundancy dispute raise contested factual issues; matter remitted for trial.
Industrial relations — unfair dismissal — termination for operational requirements — requirement to consult — appropriateness of summary disposal where factual disputes exist — IRC procedure and pleadings — remit for trial — no order as to costs (s72 LRA).
3 November 2017
2 November 2017
Leave to issue third‑party notice dismissed; dispute is commercial and belongs in the Commercial Court; costs awarded.
Procedure — Third‑party notice (Order 19 Rule 1) — Jurisdiction — Commercial dispute falling within Commercial Court under section 6(A)(1) Courts Act — Commissioner for Lands v Deeds Registrar — land law; Deeds Registration Act; Land Act.
1 November 2017
Constructive desertion upheld where spouse unjustifiably denied conjugal rights and accusations of adultery were unproven.
Family law – Constructive desertion – Denial of conjugal rights – Sufficiency of evidence of adultery – Marriage, Divorce and Family Relations Act s48(1) – Appeal by rehearing – No basis for retrial.
1 November 2017
Court upheld dismissal for collusion and dishonesty, finding substantive and procedural fairness despite telephonic summons.
Employment law – unfair dismissal – disciplinary procedure – dishonesty/collusion in sales transactions – s.27 Employment Act (particulars of employment) not determinative – s.57 fairness of reasons and procedure – telephonic disciplinary summons.
1 November 2017
Conflicting subordinate court distributions of matrimonial property were set aside; a senior magistrate ordered to re-distribute within 30 days.
Matrimonial property distribution – Conflicting subordinate court orders – Procedural irregularities in distribution records – Setting aside defective orders – Re-assignment to Chief Resident Magistrate or senior delegate – Supervisory accountability.
1 November 2017
October 2017
A stay pending appeal was granted because enforcement would likely render the appeal nugatory and harm the respondent.
Civil procedure – stay of execution pending appeal – discretion to grant stay where appeal would be rendered nugatory – applicant bears burden to show special circumstances, inability to repay, and balancing of equities.
31 October 2017
31 October 2017
Division of matrimonial property: assets acquired during marriage are joint; sales and proceeds divided considering contributions and child custody.
Family law – Distribution of matrimonial property – Assets acquired or improved during marriage form joint/matrimonial property; considerations: contribution, custody, income; sale and division of proceeds; allocation of movables; sale via Registrar due to animosity.
30 October 2017
On intestacy, estate property must be fairly distributed between widow and children; court ordered sale and equal division of proceeds.
Intestacy — application of Sections 16 and 17 Wills and Inheritance Act — fair distribution among widow and children — sale of estate property and equal division of proceeds — protection against hardship to dependants
30 October 2017
Appellant established customary ownership; trial court misdirected itself; appeal allowed and permanent injunction granted to the appellant.
Customary land – ownership and occupation – role and weight of village chiefs’ testimony – civil standard of proof (balance of probabilities) – appellate rehearing and misdirection by trial court
25 October 2017
Accused acquitted where evidence failed to connect him to a mob homicide; court criticised substandard police investigation.
Criminal law – Homicide – Mob justice – Adequacy of police investigation – Evidence linking accused – Acquittal for lack of connection.
25 October 2017
A GVH allocation and open development confer permanent usage rights where the owner delays asserting rights.
Customary land – communal ownership – chiefs’ authority to authorize use and occupation – allocation by Group Village Headman – laches/sitting on rights – permanent rights of usage and occupation
24 October 2017
Summary judgment granted where defendant failed to file opposing affidavit and alleged, unparticularised defence was a sham.
Civil procedure — Summary judgment (Order 14 RSC) — Defendant must file affidavit with particulars of bona fide defence — General denial/sham defence insufficient — Unsubstantiated allegations do not defeat summary judgment.
19 October 2017
Court refused dismissal for want of prosecution despite inordinate delay, ordering strict timelines to settle the record or face sanctions.
Civil procedure – dismissal for want of prosecution – inordinate and inexcusable delay – case management – directions to settle record – stay of execution – sanction of vacatur and execution.
18 October 2017
Court finds ACB had reasonable and probable cause to arrest and prosecute; all claims dismissed with costs.
False imprisonment; malicious prosecution; reasonable and probable cause; evidence of funds transfer and vehicle registration; plea bargaining and state witness arrangement; damages for reputation and loss of income.
13 October 2017
Applicant's bail refused; court stressed 90-day pre-trial limit, burden of exceptional circumstances, and ordered committal and disclosure timeline.
Criminal procedure — Bail applications — Pre-trial detention limit (section 161G, 90 days) — Burden on accused to show exceptional circumstances to depart from limit — State obligation to bring accused to trial and disclose witnesses — Legal aid funding and donor influence on interests of justice.
5 October 2017
Timesheets are not mandatory for taxation of costs; their absence does not bar taxation proceedings.
Civil procedure — Taxation of costs — Order 62 r.29 — Supporting documents — Whether timesheets are mandatory — Absence does not invalidate taxation.
2 October 2017
1 October 2017