High Court of Malawi - 2017 June

44 judgments

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44 judgments
Citation
Judgment date
June 2017
30 June 2017
Whether the Rules of the Supreme Court remain applicable in the High Court after repeal of section 29 of the Courts Act.
Civil procedure – summary judgment – applicability of Rules of the Supreme Court after repeal of section 29 of the Courts Act – General Interpretation Act ss 13 and 14(1)(e) preserving subsidiary legislation – procedural lacunae remedied by interpretation provisions.
27 June 2017
26 June 2017
26 June 2017
Assessment of personal injury damages: plaintiff awarded K1,505,000 for wrist fracture-related losses and incurred report costs.
Personal injury – assessment of damages – non-pecuniary damages for fracture, pain and suffering, loss of amenities and disfigurement – special damages must be pleaded and proved; reasonable compensation may be awarded where proof lacking – reliance on prior awards for quantum adjustment.
26 June 2017
26 June 2017
Petition improperly filed under subordinate rules, guardian ad litem report misused, and duplicate filing amounted to abuse of process; petition struck out.
Adoption — procedural compliance with Adoption of Children (High Court) Rules; guardian ad litem appointment and confidentiality; duplicate petitions and judge shopping as abuse of process; ethical obligations of counsel in adoption proceedings.
23 June 2017
Whether an insurer’s passenger-exclusion is void when Section 144(b) mandates cover for passengers for hire or reward.
Road Traffic Act ss 144(b) and 148 – Motor vehicle insurance – Passenger exclusion in policy – Validity where passengers are carried for hire or reward – Third-party right to sue insurer.
23 June 2017
Defamatory newspaper photo-caption of plaintiffs as corrupt; court awards MK3,000,000 each.
Defamation — Assessment of damages — Newspaper publication juxtaposing officers' faces with criminal imputation — Wide circulation and use of photographs — Absence of apology aggravating injury — General damages awarded.
23 June 2017
23 June 2017
20 June 2017
Registrar assessed personal injury damages, awarding K1,413,500 for pain, loss of amenities and special damages; costs to plaintiff.
Personal injury — Assessment of damages — Pain and suffering and loss of amenities — Special damages for medical and police reports — Burden of proof in civil negligence — Balance of probabilities — Reliance on medical report and comparative awards — Costs follow the event — Right to appeal to Judge in Chambers.
20 June 2017
Assessment of damages for pain, disfigurement and special expenses after default judgment in a road accident.
Personal injury — Assessment of damages following default judgment — Pain and suffering; loss of amenities; permanent disfigurement; special damages; 6% incapacity; costs follow the event.
20 June 2017
Ex parte injunction discharged because the applicant suppressed a material email, breaching the duty of full disclosure.
Civil procedure – ex parte interlocutory injunction – duty of full and frank disclosure – suppression of material facts (email DM2) – materiality and discharge of injunction; disciplinary/complaints procedure and natural justice (not determined).
19 June 2017
19 June 2017
Commercial disputes must be heard in the Commercial Division; failure to transfer risks dismissal and costs.
Courts Act (Amendment) 2016 — definition of 'commercial matter' — section 6A transfer to Commercial Division — Registrar's duty to transfer — commencement in wrong division — costs under s.6A(3) — urgency insufficient to avoid statutory transfer — interlocutory injunction conditional on transfer.
19 June 2017
Plaintiff's claim dismissed for want of prosecution; defendant's counterclaim granted and damages to be assessed.
Contract law – breach and specific performance – dismissal for want of prosecution – counterclaim granted in plaintiff’s absence – damages to be assessed by Assistant Registrar – costs awarded.
19 June 2017
Assessment of personal injury damages: MK2,000,000 general damages; special damages only if pleaded and proved.
Assessment of damages – personal injury – general damages for pain and suffering and loss of amenities – reliance on comparable awards; special damages must be specifically pleaded and strictly proved; unpleaded heads of damages (loss of expectation of life, loss of dependency) not recoverable.
19 June 2017
16 June 2017
Assessment of damages for a child’s road accident injuries: quantum for pain, loss of amenities, disfigurement, and modest special expenses.
Personal injury – assessment of damages – road traffic accident involving child – permanent deformity and persistent pain – awards for pain and suffering, loss of amenities, disfigurement – proof of special damages and reasonable compensation for incidental expenses.
16 June 2017
Revocation of fraudulently obtained limited letters of administration and cancellation of unlawful land registration due to existing caution.
Succession and probate – letters of administration – fraudulent/non‑disclosure in obtaining limited grant – revocation of grant; Land registration – effect of caution – unlawful registration and rectification of register; Will construction – clause prohibiting transfer of charged property.
16 June 2017
Driver negligence caused the accident; insurer's exclusion for "hire or reward" passengers did not apply to plaintiffs.
:[
15 June 2017
13 June 2017
Bail pending appeal denied for convicted foreign nationals due to flight risk and lack of exceptional circumstances; forfeiture stayed.
Criminal law – bail pending appeal – convicted offenders – discretionary and requires exceptional/unusual circumstances; risk of flight of foreign nationals; stay of forfeiture on appeal under s.149(3) CP&E Code; appellate prospects assessed but not determinative at bail stage.
12 June 2017
Plaintiff's claims for false imprisonment, defamation, and malicious prosecution dismissed; defendant reported to police and awarded costs.
Tort — False imprisonment — Liability where a private party 'directs' police arrest; Defamation — arrest and court attendance alone not necessarily defamatory; Malicious prosecution — requirement to prove initiation, lack of reasonable and probable cause, and malice.
12 June 2017
Interlocutory injunction granted to preserve clergy membership pending trial on validity of church conference and excommunication.
Interlocutory injunctions — American Cyanamid principles — preservation of status quo; Church governance — authority to convene Annual Conference; Power to excommunicate clergy; Natural justice — right to be heard; Adequacy of damages.
12 June 2017
Appeal against sentence in trafficking convictions; court corrected misrecorded charges and adjusted concurrent custodial terms.
Criminal law – Trafficking in persons – Proper statutory charge (sections 14, 15, 16(1)(c)) – Sentencing discretion – manifestly excessive test – substitution/correction of charges where victim’s age or mental capacity misrecorded.
12 June 2017
Applicant's challenge to a chief's appointment dismissed because only the President may appoint chiefs; respondents were wrong parties.
Administrative law – judicial review – proper parties; Attorney General not a proper respondent in judicial review unless office privy to challenged decision; Chiefs Act s.4 – appointment/recognition of chiefs vested in the President; action dismissed for being directed at wrong parties; interim stay discharged.
9 June 2017
Customary land sales are unenforceable; respondent’s inheritance upheld and the appellant’s appeal dismissed with costs.
Customary land — communal ownership and administration by chiefs — alleged sale of customary land unenforceable; burden and credibility of evidence in land disputes; limitation defence misconceived.
8 June 2017
Application for judicial recusal dismissed: alleged bias grounded in procedural disputes and improper attempts to add parties was unreasonable.
Recusal — apprehension of bias — test of the reasonable and fair‑minded observer; procedural complaints do not alone establish bias; adding parties requires proper application; recourse is by appeal, not judicial disqualification.
8 June 2017
8 June 2017
7 June 2017
Assessment of dismissal compensation involving factual issues requires a quorate IRC; a Chairperson sitting alone renders the decision a nullity.
Labour law — Industrial Relations Court — quorum requirement (s.67 Labour Relations Act) — assessment of compensation involves questions of fact and law — Chairperson sitting alone incompetent — decision nullity; jurisdiction — acquiescence does not confer jurisdiction.
7 June 2017
Failure to explain plea consequences and statutory defilement defence to unrepresented accused rendered the trial unfair; accused discharged absolutely.
Criminal procedure – recording of guilty plea – proviso to s.251(2) (ascertainment of understanding and consequences) – failure renders plea defective; Criminal law – defilement – statutory defence of reasonable belief as to age – duty to inform unrepresented accused; Remedy – conviction quashed/sentence set aside and discharge under s.337(1)(b) where mitigating circumstances exist.
7 June 2017
7 June 2017
Accused convicted of murder for a joint, armed attack; provocation and self-defence not made out.
Criminal law – Murder – Joint enterprise liability – Malice aforethought established by use of dangerous weapons – Provocation and self-defence rejected.
7 June 2017
Appellate court reduced a deterrent custodial sentence for unlawful possession of prescription medicines but upheld concurrent sentence on related property offence.
Criminal law – sentencing – first offenders – application of ss 339 and 340 Criminal Procedure and Evidence Code; sentencing discretion; deterrent custodial sentence justified where diversion of prescription medicines causes significant public harm; substitution and mitigation of sentence on appeal.
6 June 2017
5 June 2017
Leave granted for judicial review of vehicle seizure amid disputed vehicle identity and alleged unpaid customs duties; case transferred to Revenue Division.
Judicial review – leave to apply – seizure of vehicle – identity of vehicle – unpaid customs duty – revenue matter – transfer to Revenue Division.
5 June 2017
Part payment without documentary proof of full settlement constitutes admission; failure to prove settlement warrants judgment on admission.
Civil procedure — Judgment on admission (Order 29) — Part payment as admission of liability — Burden to prove full and final settlement — Evidentiary requirement for settlement documentation.
1 June 2017
Interim injunction granted to restrain alleged unlawful transfer of village headship pending customary succession dispute.
Injunctions – Interim relief to preserve status quo – Disputes over customary leadership succession – Chewa customary authority and lineage claims – Role of affidavit evidence in interlocutory relief.
1 June 2017
Registrar erred by deciding disputed factual issues under Order 14; appeal allowed and ruling set aside with costs.
Civil procedure – Appeal from Registrar – Order 14 RSC – Improper summary disposal of disputed factual issues – Rescission of sale – Local authority powers (s.35 Local Government Act) – Contractual privity – Remittal for full hearing.
1 June 2017
Appellate court upheld lower court's credibility finding in a customary land dispute and dismissed the appeal with costs.
Customary land – communal ownership – chiefs’ power to authorize use under Land Act ss.25–26 – limits of chiefs’ authority – allocation vs individual title; civil proof on balance of probabilities; credibility findings on customary land disputes; relationship between Traditional Authority determinations and court jurisdiction.
1 June 2017
1 June 2017