High Court of Malawi - 2017 December

18 judgments

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18 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