High Court of Malawi - 2019

222 judgments

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222 judgments
Citation
Judgment date
July 2019
Petition filed after mandatory seven-day period was statute-barred; court struck it out and ordered each party to bear its own costs.
Electoral law – computation of statutory seven-day period for election petitions – communication/ service date as trigger – General Interpretation Act and Civil Procedure Rules govern inclusion of weekends/public holidays – petitions filed after statutory period are statute-barred and subject to striking out; court cannot extend mandatory limitation.
9 July 2019
An election petition filed after the seven‑day statutory period is statute‑barred and must be struck out.
Election law – section 97 Local Government Elections Act – computation of the seven‑day limitation – General Interpretation Act and court rules – weekends/public holidays – statutory limitation and jurisdiction – condonation of late election petitions – striking out as incompetent.
9 July 2019
8 July 2019
Court awarded K4,700,000 for severe head and soft‑tissue injuries, guided by comparable awards and currency devaluation.
Personal injury — assessment of damages — non‑economic loss (pain and suffering, loss of amenities, disfigurement) — use of comparable awards and adjustment for currency devaluation.
3 July 2019
3 July 2019
June 2019
27 June 2019
26 June 2019
26 June 2019
Assessment of damages after unfair dismissal: employer's refusal to reinstate triggers statutory 12‑week award; lost salary, bonus and pension to judgment awarded.
Employment law – unfair dismissal – reinstatement order not complied with – assessment of damages – section 63 Employment Act – special 12‑week award – lost salary and withheld bonuses – pension contributions to date of judgment – burden of proof; employer's duty to produce payroll records.
24 June 2019
Divorce granted for cruelty; young child's custody awarded to mother based on best interests despite customary lobola claims.
Jurisdiction under the Marriage, Divorce and Family Relations Act 2015 – application of corresponding provisions to repealed enactments; Divorce – irretrievable breakdown via cruelty (repeated beatings; domestic violence plea); Child custody – best interests paramount, statutory preference for mother of young child; Customary lobola does not override child's welfare.
21 June 2019
The defendant negligent for failing to carry an extinguisher and stop timely; claimant 80% contributorily negligent for loading a hot mini-cooker.
Negligence – duty of care in employer-provided transport; res ipsa loquitur inapplicable where plausible alternative cause exists; contributory negligence for loading hot appliance; failure to carry extinguisher and to stop promptly as negligent omissions; special damages require strict proof.
20 June 2019
20 June 2019
14 June 2019
A parliamentary election petition grounded on sections 100 and 114(1) was misconceived; s100 applies only to presidential petitions and s114(1) requires a Commission decision on irregularity.
Electoral law – Parliamentary elections – Proper statutory basis for election petitions – Section 100 applies only to Presidential petitions; Section 114(1) permits appeals only against Commission decisions confirming or rejecting irregularities; failures under section 113 may require judicial review, not appeal under s114.
13 June 2019
13 June 2019
A s.114 election appeal requires a prior Commission decision; absent that, the petition was misconceived and dismissed.
Electoral law - Parliamentary elections - s.114 appeal limited to decisions of the Electoral Commission on complaints - s.113 complaints procedure - distinction from presidential petitions (s.100) - jurisdiction and judicial review - procedural compliance (CPR).
12 June 2019
A section 114 election petition is incompetent absent a prior Commission decision on the alleged irregularity.
Electoral law; s.114 Parliamentary and Presidential Elections Act — appeal lies only from a Commission decision confirming/rejecting irregularity; complaints under s.113 required first; judicial review distinct remedy; grounds for voiding election limited to s.114(3).
12 June 2019
Admissibility of a deceased witness's statement and whether the accused have a prima facie case to answer.
Criminal procedure – Admissibility of written statements of unavailable/deceased witnesses – Sections 173 and 175 CP&EC – Right to a fair trial and to challenge evidence – 'Case to answer' test (whether a reasonable tribunal might convict).
11 June 2019
Misnaming the Electoral Commission is not fatal; applicant may amend, judicial review permitted, interlocutory injunction to restrain swearing-in refused.
Administrative law – judicial review of electoral decisions; procedural irregularity of party citation – misnaming and estoppel; interlocutory relief – restraint on swearing-in of declared MP; election law – judicial review versus election petition; procedural requirements for urgent oral applications.
5 June 2019
4 June 2019
Court convicted three accused of murder and conspiracy; acquitted them of selling/possession of human tissue; fourth accused acquitted on alibi.
Criminal law — Murder and conspiracy to kill a person with disability — Admissibility and weight of retracted confessions when corroborated — Alibi not challenged — Insufficient proof of possession/sale of human tissue.
4 June 2019
3 June 2019
May 2019
Appellate court ordered retrial on property distribution, child maintenance and compensation due to lower court omissions.
Family law — Dissolution of marriage — Distribution of matrimonial property — Lower court distributed property without hearing — Absence of maintenance and compensation orders — Appellate powers (Courts Act s.22) — Retrial ordered; preservation of property pending retrial; costs each party.
27 May 2019
Court granted leave for judicial review of electoral actions but discharged the stay, allowing the Commission to complete processes under statutory time limits.
Electoral law — Judicial review as a permissible route for election disputes — Jurisdiction under section 76(5)(a) and Order 19 r.20 — Interim injunctions in election matters — Statutory timeliness under s.99 Parliamentary and Presidential Elections Act — Reviewability of administrative acts (tally sheets, verification, tabulation).
27 May 2019
Prisoner passenger owed duty of care but failed to prove driver negligence or causation due to lack of evidence.
Personal injury — Negligence — Duty of care owed to prisoner passengers — Goods vehicle conveying persons without adaptation — Statutory breaches (insurance, fitness certificate) — Causation and need for medical evidence — Contributory negligence considered.
23 May 2019
Prisoner passenger owed duty of care, but insufficient proof of driver negligence and causation; claim dismissed.
Tort — negligence — duty of care of prison authorities to prisoner-passenger; authorization to be carried; evidential burden on breach and causation; statutory breaches (carrying passengers in goods vehicle; insurance; certificate of fitness) noted but not shown to establish negligence; failure to tender medical evidence defeats causation.
23 May 2019
Claimant awarded conversion and nominal loss-of-use damages where market and usage evidence were insufficient.
Conversion of chattel – delivery to purchaser before full payment – measure of damages for non-runner vehicle – replacement market value where repair cost not applicable – loss of use claims require proof of period and purpose of use – mitigation of loss.
23 May 2019
Claimant proved accident-related injuries and was awarded K2,700,000 for pain, suffering, disfigurement and loss of amenities.
Personal injury — proof of injuries; default judgment — liability settled; assessment of general damages — pain and suffering, disfigurement, loss of amenities; special damages and loss of earning capacity — proof required; quantum — comparative approach.
23 May 2019
Divorce granted for cruelty where respondent abandoned the matrimonial home and no collusion was found.
Family law – Divorce – Cruelty as ground for divorce – abandonment/denial of conjugal rights – requirement of intentional conduct making cohabitation impossible; Collusion inquiry under Divorce Act s7; Ancillary reliefs must be particularized to be granted; Costs – each party to pay own.
23 May 2019
Internal administrative misplacement of served process does not justify setting aside a default judgment.
Civil procedure – Setting aside default judgment – Order 12 r.21 – Requirement of reasonable cause for failure to defend – Need to show meritorious defence with real prospects – Internal administrative loss of process not sufficient – Procedural justice integral to substantive justice.
20 May 2019
Appeal dismissed: maintenance directive upheld as order, customary-house claim unproven, and property-distribution issue prematurely raised.
Family law – maintenance orders – statement that respondent "should continue supporting the child" constitutes maintenance order; specifics require factual inquiry at first instance; Customary law – obligations under matrilineal custom must be proved in trial court and cannot be raised afresh on appeal; Civil procedure – appellate court will not adjudicate issues not determined by lower court.
20 May 2019
17 May 2019
16 May 2019
15 May 2019
13 May 2019
Interlocutory injunction vacated where claimant failed to file for continuation and did not prosecute the scheduled hearing.
Civil procedure – interlocutory injunction – continuation hearing – failure to file application for continuation – vacatur of injunction without notice.
13 May 2019
13 May 2019
10 May 2019
Judge recused after defence sought to lead evidence implicating the judge's close relative; file transferred for reassignment.
Judicial recusal – perceived bias and impartiality – familial relationship of judge to person implicated in evidence – defence conduct and late amendments to witness statements – expungement of evidence and limits on media reporting – transfer of file for reassignment.
10 May 2019
Court awarded K5.3m to the claimant for serious wrist fractures, pain, disfigurement and loss of amenities.
Personal injury — Assessment of damages — Open fracture of distal radius and ulna — Pain and suffering and disfigurement — Loss of amenities — Quantum — Permanent incapacity assessed at 25% — Costs for reports not proved.
8 May 2019
8 May 2019
7 May 2019
Assessment of damages for injuries from negligent driving, including general damages, disfigurement, special damages and costs.
Motor vehicle negligence; assessment of damages; pain and suffering; loss of amenities; disfigurement; special damages (police and medical reports); consent judgment on liability; absent defendants.
4 May 2019
3 May 2019
A Third Grade Magistrate lacked jurisdiction to determine child custody; custody must be decided by a child justice court.
Child Care, Protection and Justice Act – custody jurisdiction – child justice courts; Jurisdiction of subordinate courts – supervisory review (s.26 Courts Act); Procedural requirements – designation of child justice courts; Presence of probation officer; Order set aside for want of jurisdiction; Referral to child justice court.
3 May 2019
3 May 2019
3 May 2019
2 May 2019
2 May 2019
2 May 2019