High Court of Malawi - 2017 May

41 judgments

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41 judgments
Citation
Judgment date
May 2017
Applicant failed to prove adultery but proved cruelty; decree nisi of divorce granted on cruelty.
Family law – applicable statute – pre-2015 marriage governed by Divorce Act; Divorce – grounds – adultery (burden and proof; circumstantial inference; condonation); Cruelty – definition, evidence and standard; Decree nisi granted for cruelty; Jurisdiction – domicile and non-collusion.
31 May 2017
Driver’s excessive speed at a zebra crossing caused the plaintiff’s injuries; insurer liable subject to statutory limit; special damages unproven.
Motor vehicle negligence — duty of care to pedestrians — excessive speed at zebra crossing — eyewitness evidence accepted — causation of fractures — special damages require strict proof — insurer liability limited by Section 148 Road Traffic Act — costs to successful party.
30 May 2017
Court struck out defendant's general-denial defence as an abuse of process for lacking a bona fide triable issue.
Civil procedure – Striking out defence – General denial – Abuse of process – Triable issue – Affidavit evidence to contradict documents – Assessment of damages versus substantive triable issue.
30 May 2017
Employer liable for false imprisonment and malicious prosecution where it procured police action; defamation claim not proved.
Tort — False imprisonment — Employer’s instigation of police action; Malicious prosecution — elements: prosecution by defendant, favorable termination, lack of reasonable/probable cause, malice; Defamation — requirement to plead and prove specific defamatory words or conduct; Failure to call key witnesses and produce documents adverse inference.
29 May 2017
Originating summons and declaratory relief cannot be used to pursue contested factual claims for damages and conversion.
Civil procedure – Originating summons – Inappropriate where substantial disputes of fact exist; Declaratory judgment – limited, discretionary remedy; cannot be used to obtain executory consequential relief (damages) in contested factual matters; Consequential relief must correspond to action capable of executory relief.
26 May 2017
Section 148 CP&EC provides only for summary restitution of property in an offender’s possession; money‑laundering recoveries require timely statutory proceedings.
Criminal procedure – Restitution under section 148 CP&EC – applies to theft (Penal Code chapters XXVI–XXXII) and summary return of property in offender’s possession; Money Laundering Act – confiscation/pecuniary orders subject to one‑year post‑conviction limitation; tracing laundered proceeds not suitable for section 148; section 29 Penal Code (commutation) irrelevant if no restitution order
25 May 2017
Whether section 148 CP&EC permits summary restitution of laundered proceeds when no stolen property was in possession at arrest.
Criminal procedure – Section 148 CP&EC – restitution by writs of restitution – applies to Penal Code theft offences only – summary restoration of property in accused’s possession at apprehension – Money Laundering Act remedies require timely confiscation/pecuniary applications – delay bars ML Act relief – section 29 Penal Code (commutation) irrelevant where no restitution order
25 May 2017
A stay pending appeal requires proof of a valid, served notice of appeal; absence of such proof defeats the stay.
Civil procedure – Stay of execution pending appeal – requirement to file and serve notice of appeal under Order XXXIII r.1(3)(4) – failure to exhibit notice defeats stay; Subordinate courts – jurisdictional monetary limit under s.39 Courts Act; Procedural form – interplay between ex parte and inter partes summons; Service and affidavit proof.
24 May 2017
Stay of execution pending appeal refused for lack of special circumstances and failure to prove respondents’ inability to repay.
Stay of execution pending appeal — applicant must show special circumstances; burden on applicant to prove respondents’ inability to repay; prospects of success on appeal not determinative; appeal does not automatically operate as a stay; protection of successful litigant’s fruits of litigation.
23 May 2017
Court clarified that a retrial ordered "within three months" requires commencement, not completion, within that period.
Criminal procedure – retrial ordered "within three months" – interpretation of temporal orders – requirement to commence retrial versus to conclude retrial – custody and release implications.
23 May 2017
Court stayed an IRC costs order pending appeal because applicant showed prospects of success and risk of a nugatory appeal.
Stay of execution pending appeal; costs orders by Industrial Relations Court; Labour Relations Act s.72(1)&(2); prospects of success; risk of rendering appeal nugatory; impecuniosity of successful litigant.
22 May 2017
Mixed labour and defamation claims must be split: unfair-termination matters to the Industrial Relations Court, defamation retained in the High Court.
Labour law – jurisdiction – Industrial Relations Court original jurisdiction – mixed claims – defamation for High Court – transfer of unfair dismissal claim.
22 May 2017
Court vacated an interim injunction over land, finding a triable issue but favouring defendant’s possession and ordering no disposal pending trial.
Land law – interim injunctions – triable issue requirement – adequacy of damages (land unique) – balance of convenience – possession and evidence of sale – injunction vacated pending trial.
22 May 2017
Court assessed and awarded MK2,900,000 for general damages; refused unproved special damages.
Personal injury — assessment of damages; general damages (pain and suffering, loss of amenities, disfigurement); special damages require strict proof; use of comparative awards and adjustment for currency devaluation; court inspection of injuries.
22 May 2017
Interim injunction discharged for non‑disclosure of DSSA expiry; dispute is commercial and must be transferred to the Commercial Division.
Commercial law – Dealer Sales and Service Agreement – Ex parte interlocutory injunction – Suppression of material facts – R. v. Kensington Income Tax Commissioners principle – Discharge of injunction – Courts Act: definition of "commercial matter" – Transfer to Commercial Division under s.6A
22 May 2017
22 May 2017
Interlocutory injunction continued to protect asserted use-and-occupation rights in customary land pending resolution of disputed authority and jurisdiction.
Customary land — rights to use and occupy (distinct from registered title) — interlocutory injunction — adequacy of damages — balance of convenience — authority of seller and jurisdiction of chief to witness customary land transaction.
22 May 2017
Insurer liable under s.148 for death caused by negligent driving; solicitor removal requires compliance with Order 67 RSC.
Motor vehicle accidents – Driver's duty of care and excessive speed – Negligence causing death – Insurer's statutory liability under section 148 Road Traffic Act – Assessment of damages for loss of dependency and expectation of life – Change/removal of solicitor on record; Order 67 RSC compliance.
22 May 2017
Applicant detained since 2015 for homicide granted bail pending trial subject to strict surety, reporting, and travel conditions.
Criminal procedure – Bail pending trial – Long remand without trial – State not opposing bail – Imposition of strict conditions including cash deposit, bonded sureties, periodic police reporting, travel restrictions and surrender of travel documents.
19 May 2017
Assessment awarded MK1,271,120 for loss of expectation of life and dependency; special damages denied for lack of proof.
Damages assessment – loss of expectation of life and loss of dependency; multiplicand-and-multiplier method; effect of currency devaluation on conventional awards; strict proof required for special damages; apportionment among dependants.
19 May 2017
Default judgment set aside for lack of service; interested party joined and defendant’s name corrected; merits to be heard urgently.
Land dispute — Default judgment — Relief from default (O19 r9; O13 r9) — Service of process — Joinder of interested third party — Correction of party name — Merits hearing urgent.
18 May 2017
Whether pre‑MRA civil service tenure transfers to MRA and correct calculation of severance, notice and redundancy entitlements.
Employment law – transfer vs secondment under statutory authority (s.27 MRA Act) – severance allowance vs contractual redundancy benefits – characterization of "ex gratia" payments – mitigation of loss – just and equitable compensation under s.63 Employment Act – adjustment for inflation/devaluation – exemplary damages and interest.
18 May 2017
Court granted interlocutory injunction preserving students' access to school pending determination of dispute over suspension/expulsion and exams.
Interlocutory injunction — American Cyanamid test — serious issue to be tried; adequacy of damages — protection of students' right to education; balance of convenience; preservation of status quo; school disciplinary process and natural justice
16 May 2017
Applicant failed to show a triable issue and used improper originating summons procedure; judicial review required and injunction vacated.
Administrative law – accreditation decisions – minimum standards versus scoring; confidentiality of evaluation criteria; interim injunction test – no triable issue where improvement plan unimplemented; procedural law – judicial review required for public law challenges (O'Reilly v Mackman exception inapplicable).
16 May 2017
Pictorial caption implying corruption held defamatory; applicants awarded damages and costs.
Defamation – publication and reference – pictorial juxtaposition with caption – imputation of dishonesty/corruption – sting v. antidote – damages and costs.
16 May 2017
Whether adverse possession under the Limitation Act can extinguish customary land rights; court affirms need to prove customary-law doctrine and upholds factual findings.
Property law – Customary land – Adverse possession – Limitation Act s6 not applicable to customary land which vests in the President (Land Act s25); proof required of any equivalent customary-law doctrine (Courts Act s64) – Appellate review of factual credibility and site visit.
16 May 2017
Assessment of fatal-accident damages: loss of expectation of life and pecuniary dependency using statutory minimum wage proxy.
Damages assessment – fatal road accident – loss of expectation of life – loss of dependency – use of statutory minimum wage as proxy for earnings – multiplier of four – dependants’ share approximately two-thirds.
12 May 2017
Court refused immediate strike-out for non-compliance, ordering filing of witness statements by deadline or else defence struck out.
Civil procedure — Failure to comply with order for directions — Order 2 RSC (cure of irregularities) — Inherent jurisdiction — Strike-out of defence — Final opportunity to comply with procedural orders.
12 May 2017
Failure of counsel to diarise a hearing does not excuse non-attendance; clients are bound by their lawyer's omissions.
Civil procedure — Restoration of struck-out actions — Non-attendance on set hearing date — Failure to diarise not a sufficient reason for restoration — Client bound by acts/omissions of counsel — Order 35 r.1 RSC; Practice Note 35/3/1.
12 May 2017
Court refused to convert judicial review to writ proceedings and ordered inter partes leave hearing to proceed.
Judicial review — Conversion to action — Order 53 r9(5) — Appropriate only where relief unsuitable for judicial review — Leave to apply for judicial review — Disputed facts, discovery and cross‑examination considerations — Wednesbury unreasonableness.
12 May 2017
11 May 2017
Summary judgment refused where plaintiff failed to authenticate documents and dispel bona fide factual disputes.
Civil procedure – Summary judgment – Order 14 – Plaintiff must verify claim and show absence of bona fide defence; authentication of documents, electronic communications and data-logger summaries essential; unresolved evidential inconsistencies preclude summary judgment.
11 May 2017
Each plaintiff awarded K1,000,000 for five days' false imprisonment for loss of liberty and humiliation.
False imprisonment — quantum of damages; compensation for loss of liberty, humiliation and mental suffering; evidentiary weight of alleged cell conditions; comparative awards and judicial discretion in assessing non-pecuniary damages.
11 May 2017
A magistrate court cannot transfer proceedings to the High Court; the purported transfer of assessment was invalid and dismissed.
Civil procedure — jurisdiction and transfer of proceedings — Courts Act ss.26, 40, 46 — subordinate courts may transfer only to other subordinate courts — High Court empowered to transfer proceedings to itself — purported transfer of assessment of damages invalid.
11 May 2017
Driver’s excessive speed and failure to keep lookout caused pedestrian's death; plaintiff awarded damages; quantum to be assessed.
Road traffic accident — negligence — driver’s duty to avoid excessive speed and keep proper lookout — causation and burden on balance of probabilities — insurer sued under s.148(1) RTA — assessment of damages by Registrar.
11 May 2017
Court ordered first defendant to file handwriting expert report by deadline or have its case deemed closed; final submissions due 30 days.
Civil procedure - expert evidence - handwriting expert - failure to produce expert report - deeming party's case closed - timetable for final submissions
10 May 2017
Registrar acted without jurisdiction; garnishee execution set aside and award funds retained by the court pending appeal.
Civil procedure – Jurisdiction – Proceedings and execution by a court officer without jurisdiction are null and void ab initio – Registrar’s ultra vires conduct – Garnishee order and payment – Funds to remain in custody pending appeal.
9 May 2017
4 May 2017
Claim to restrain bank sale failed where written loan agreement barred verbal amendment and claim disclosed no cause of action.
Contract law — Entire agreement clause and requirement for written, signed amendments; Pleadings — failure to plead key allegations; Civil procedure — strike out for disclosing no cause of action; Injunctive relief — cannot be based on unpleaded or verbal variations to a written loan agreement.
1 May 2017
Uncontested petition: respondent's deceit, arson and fraud found to constitute cruelty, justifying divorce and costs.
Matrimonial law – Divorce – Cruelty as ground for dissolution – Uncontested petition and unchallenged evidence – Conduct including deceit, insurance fraud and arson constituting cruelty – Domicile and absence of collusion.
1 May 2017
Uncontroverted passenger evidence established driver negligence and insurer vicarious liability; damages to be assessed by the Registrar.
Motor vehicle accident – driver negligence – passenger's uncontroverted evidence – vicarious liability of insurer – assessment of damages by Registrar.
1 May 2017