High Court of Malawi - 2017 February

31 judgments

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31 judgments
Citation
Judgment date
February 2017
An interlocutory injunction was discharged after parties’ without-prejudice settlement was found to have been agreed, constituting changed circumstances.
Interlocutory injunction — discharge where settlement accepted post-injunction; "without prejudice" correspondence — admissible to prove contract where terms accepted; clerical error in citing procedural rule — falsa demonstratio non nocet.
28 February 2017
Plaintiff proved driver’s negligence while crossing road; defendant insurer held wholly liable.
Road‑traffic negligence — driver’s duty of care to avoid excessive speed and keep proper lookout — proof on balance of probabilities — contributory negligence must be proved by defendant — insurer liable under Road Traffic Act.
28 February 2017
Court allowed late amendment to defence, finding prejudice compensable by costs and ordering incorporation into joint defence.
Civil procedure — Amendment of pleadings (Order 20) — Late amendment — Prejudice that cannot be compensated — Joint defence versus separate defence — Costs as compensation.
28 February 2017
Plaintiff failed to prove driver negligence; pedestrian's breach of duty led to dismissal of claim against insurer.
Insurance cover proved; burden of proof on plaintiff; negligence requires proof of driver breach; pedestrians owe duty under Road Traffic Act; inconsistent evidence defeats claim.
28 February 2017
Assessment of catastrophic personal injury damages: substantial non-pecuniary awards granted; special damages denied for lack of proof.
Personal injury — assessment of damages — non-pecuniary awards for pain and suffering, loss of amenities and disfigurement; special damages must be pleaded and proved; use of comparable awards and adjustment for economic change; permanent incapacity considered.
23 February 2017
Appellant entitled to disputed land under Mang'anja matrilineal custom and by registration/possession; trial court's orders set aside.
Customary land succession — Mang'anja matrilineal versus patrilineal inheritance; evidentiary weight of occupation and association registration; appeal re‑examination where trial record lacks reasoned judgment.
20 February 2017
20 February 2017
Appeal allowed: causes of action against a deceased survive to the estate and only an authorised administrator may defend; excessive delay and misrepresentation constituted abuse.
Succession law — s.10(1) survival of causes of action — requirement for letters of administration/authority to defend deceased’s estate — standing to be joined; Civil procedure — inordinate delay and abuse of process in applications to set aside default judgment; Misrepresentation by counsel as abuse of process.
17 February 2017
Assessment of damages for severe leg fractures: quantum for pain, loss of amenities, disfigurement; special damages unproven.
Personal injury — Assessment of damages for multiple leg fractures and surgical insertion of rods — quantum for pain and suffering, loss of amenities and disfigurement — special damages (police/medical reports) must be pleaded and proved — use of comparable awards and consideration of inflationary adjustments.
16 February 2017
Driver's excessive speed and failure to keep lookout caused the ox‑cart collision; owner and insurer held fully liable.
Motor vehicle negligence — duty of care — excessive speed and failure to keep lookout — causation; contributory negligence; insurer's policy limits not established; assessment of damages by Registrar.
16 February 2017
Court refused to suspend committal order due to defendants' persistent non‑compliance and unclean hands.
Civil procedure — committal and suspension under Order 52 r 7 — discretionary relief — non‑compliance with court orders; unclean hands; improper attempt to vary injunction via suspension.
15 February 2017
Whether a preliminary application incident to another application must be instituted by summons or may proceed by notice.
Civil procedure – preliminary applications incident to other proceedings – Order 32 r.1 summons requirement – Order 2 r.1 cure for irregularity – abuse of court process.
14 February 2017
The respondent insurer was held liable under section 148 for its insured’s negligent speeding and failure to keep proper lookout, causing the applicant’s injuries.
Road traffic law – Negligence – Duty of care to pedestrians – Excessive speed and failure to keep proper lookout – Causation – Insurer’s liability and right of injured party to sue under section 148 Road Traffic Act.
13 February 2017
Unilateral re‑designation, repeated transfers and degrading treatment amounted to demotion and constructive dismissal; damages remitted for assessment.
Employment law — constructive dismissal — demotion can occur without salary reduction — objective effect of unilateral re‑designation and transfers — requirement of procedural fairness and natural justice — concurrent jurisdiction of High Court and labour forums.
13 February 2017
Series of unilateral re-designations, transfers and humiliating treatment constituted constructive dismissal; matter remitted for damages assessment.
Employment law – constructive dismissal – section 60 Employment Act – unilateral re-designation and transfers as demotion – procedural fairness and natural justice – High Court concurrent jurisdiction in labour matters.
13 February 2017
Plaintiff proved truck driver negligence; vehicle insurer liable under Road Traffic Act; interest claim dismissed.
Road Traffic Act s148 — insurer's liability; Civil standard of proof — balance of probabilities; Contributory negligence — burden on defendant to prove material contribution; Interest on damages — not automatic where claim is for damages rather than debt; Weight of uncontroverted oral evidence and failure to call defence witnesses.
10 February 2017
Appellant’s failure to set down appeal for over two years warranted dismissal for want of prosecution and release of funds to respondents.
Civil procedure – Dismissal for want of prosecution – Inordinate and inexcusable delay – Prejudice to successful litigant – Setting down appeal (Order 59 r.5; Order 34 r.2) – Right to restore – Release of funds paid into court.
10 February 2017
Plaintiff proved motorcycle rider's negligence causing a child's death; insurer held directly liable under Road Traffic Act s.148(1).
Motor-vehicle negligence – duty of care to pedestrian children – child not contributorily negligent; insurer’s direct liability under Road Traffic Act s.148(1); damages for loss of expectation of life and dependence; quantum to be assessed by Registrar.
10 February 2017
The defendant breached statutory duties by failing to provide specialized training and supervision, causing the plaintiff's injury.
Occupational Safety, Health and Welfare Act – employer’s duty to provide safe place and system of work – obligation to provide specialized instruction, training and supervision for dangerous machinery – breach of statutory duty – res ipsa loquitur inapplicable where cause known – protective devices not required where unnecessary.
8 February 2017
Where a written judgment is incomplete, courts assess the materiality of the omission; reconstruction or completion may be ordered rather than automatic quashing of conviction.
Criminal procedure – requirement for written judgments (s.140 CP&EC) – failure to deliver complete written reasons – effect depends on materiality of missing parts – possible remedies include reconstruction, retrial or discharge – right of appeal and fair trial implications.
8 February 2017
Final inter‑country adoption granted where petitioner met residence, suitability and the infants’ best‑interests requirements.
Adoption law – inter‑country adoption; residence requirements; psychosocial adoptability; best interests of the child; consent of next of kin; apostilled home‑study reports; timeliness and permanence; final versus interim adoption orders.
7 February 2017
7 February 2017
Court preserved interlocutory injunction protecting students’ studies pending trial, finding serious issues and damages inadequate.
Interlocutory injunction – American Cyanamid principles – Serious issue to be tried – Adequacy of damages – Balance of convenience – Accreditation and deregistration powers of National Council for Higher Education – Retrospective effect of accreditation decisions.
6 February 2017
Medical illness and prison conditions did not amount to exceptional circumstances to grant bail pending appeal.
Criminal law – bail pending appeal – conviction terminates ordinary right to bail – exceptional circumstances required for bail of a convict – medical condition and prison overcrowding insufficient where prisoner receives hospital care – offence: possession of protected species (ivory).
4 February 2017
An interlocutory mandatory injunction was granted to the applicant pending trial on a triable dispute over alleged sub‑letting.
Interlocutory injunction – triable issue – alleged sub‑letting – adequacy of damages – balance of convenience – mandatory injunction – allocation to new tenant.
3 February 2017
Owner held liable for driver's negligence; insurer not liable due to failure to prove insurance.
Negligence — duty of care of driver — owner liability for driver's negligence — insurer liability under s.148 Road Traffic Act — proof of insurer — requirement to plead and prove special damages.
3 February 2017
Whether judgment debt should be paid into court pending determination of an application to set aside a default judgment.
Civil procedure – garnishee proceedings; payment of judgment debt into court; setting aside default judgment; assessment of damages – adequacy of reasons; abuse of process; registrars' orders; risk of appellate interference.
2 February 2017
Irretrievable breakdown is not a statutory ground under the Divorce Act; petition for divorce dismissed with costs.
Divorce law – applicability of Marriage, Divorce and Family Relations Act to pre-commencement marriages – governing law for marriages contracted before 3 July 2015; Divorce Act s.5 – prescribed grounds for divorce; irretrievable breakdown not a statutory ground; petition dismissed with costs.
2 February 2017
Court dismissed third party's appeal and set aside stay for inordinate delay, procedural irregularity and abuse of process.
Civil procedure – appeal – want of prosecution – inordinate delay and contumacious conduct – dismissal for want of prosecution; Civil procedure – stay of execution – procedural route via Registrar – jurisdictional/irregularity issues; Abuse of court process – using delay to frustrate enforcement of judgment; Costs to follow the event.
1 February 2017
Compensation for unfair dismissal under s.63 must be just, equitable and individualized; blanket awards require reassessment.
Employment law – Unfair dismissal (s.57) – Compensation assessment (s.63) – Just and equitable principle – Duration of service primary – Not compensation to retirement – Requirement for individualized assessment and reasons – Remittance for reassessment.
1 February 2017
Court amended matrimonial property order: allow buyout or, after 14 days without agreement, order sale and share proceeds per formula.
Matrimonial property division; Amendment/correction of judgment under Order 20 Rule 11; buyout option; compulsory sale if no agreement within 14 days; application of distribution formula.
1 February 2017