High Court of Malawi - 2021

386 judgments

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386 judgments
Citation
Judgment date
June 2021
A trial court need not give reasons when finding the applicant has a case to answer.
Criminal procedure – Section 254 CP&E Code – finding of a case to answer – no statutory duty to give reasons when directing accused to make defence – review jurisdiction and non-interference with ongoing subordinate court proceedings.
15 June 2021
Leave granted to seek judicial review of COVID-related restrictions; injunction dismissed; police dismissal overturned for procedural unfairness.
Judicial review – Public health measures – Partial lockdown and restrictions on trade and movement – Amenability to judicial review – Lawfulness and procedural fairness; Interlocutory injunction – requirement for separate application and supporting affidavit; Administrative law – disciplinary proceedings – procedural fairness, inadequate notice, internal interference, functus officio; Ultra vires and parliamentary oversight – Public Health Amendment Rules.
15 June 2021
Leave for judicial review refused where no recorded hospital decision, no medical evidence under s.243, and alternative remedies available.
Administrative law – leave to apply for judicial review – necessity of a recorded public decision; Abortion law – section 243 Penal Code exception for operations to preserve mother's life; Alternative remedies – criminal prosecution and child maintenance bars to review; Wednesbury unreasonableness; Onus on applicant to produce medical evidence.
15 June 2021
Leave for judicial review refused where no hospital decision to deny termination was recorded and alternative remedies existed.
Judicial review — leave to apply — requirement of a justiciable public decision; Penal Code s243 exception — onus to show risk to mother's life/health; locus standi; alternative remedies (criminal prosecution, child maintenance); abuse of process.
15 June 2021
Section 46 requires the Commissioner to refer questions of law to the High Court on request; refusal is irrational, mandamus granted.
Workers Compensation Act s46 – mandatory duty to state a special case to the High Court on request; judicial review – Wednesbury unreasonableness; mandamus to compel statutory duty; distinction between case stated and appeal procedures.
15 June 2021
Adoption authorized after court found statutory requirements, valid consents, and best interests of the child satisfied.
Adoption law – Adoption of Children Act requirements – child’s age and residency – petitioners’ age and marital status – consent of persons with parental interest – Guardian ad Litem recommendation – best interests of the child – prohibition on payment for adoption.
14 June 2021
Subordinate court may distribute matrimonial property as ancillary to dissolving a customary marriage; distribution depends on intention and contributions.
Family law – Dissolution of customary marriage – Ancillary power of subordinate court to distribute matrimonial property notwithstanding statutory monetary limits – Distribution based on intention and contribution (Sikwese v Banda) – Pre-Act marriages and inapplicability of section 74 – Credibility findings and evidential assessment.
14 June 2021
Costs assessed on the standard basis: counsel’s K40,000 hourly rate allowed, several claimed hours reduced as disproportionate.
Civil procedure — Assessment of costs — Standard basis where order silent — Proportionality and reasonableness of hours — Counsel hourly rate — Reduction for non-compliance with assessment bundle rule — Messengerial attendances not taxable at counsel rates — 60% allowance for general care and conduct in straightforward personal injury matter.
14 June 2021
10 June 2021
9 June 2021
Court validated an unratified pre-incorporation land transfer under Companies Act s44, making the company a proper party.
Companies Act s44 – pre-incorporation contracts – requirement and form of ratification – validation by court of unratified pre-incorporation land transfer – capacity to sue – proper party to proceedings.
9 June 2021
9 June 2021
8 June 2021
Application for rehearing and to set aside judgment dismissed; High Court functus officio after Supreme Court appeal.
Civil procedure – application for rehearing and to set aside judgment entered in absence of a party – functus officio – finality of judgment after appellate determination; High Court cannot reopen matter adjudicated on appeal.
8 June 2021
Court stayed enforcement of procurement-review remedies pending judicial review due to arguable illegality, possible bias, and reputational risk.
Administrative law — stay of execution pending judicial review; procurement law — Review Committee remedies; duty of tribunal to give reasons; undeclared interest and apprehension of bias; serious issue to be tried, irreparable harm, balance of convenience.
8 June 2021
7 June 2021
Court enhanced sentence to 40 years for defilement of a nine‑year‑old by an HIV‑positive, premeditating offender.
Criminal law — Defilement — Sentencing on confirmation — Whether ten years was unduly lenient for defilement of a nine‑year‑old — Aggravating factors: victim age, HIV‑positive offender, premeditation, threats and bribery — Movement from 14‑year to higher baseline starting point.
7 June 2021
Assessment of damages for fractured tibia: non-pecuniary award and modest special damages for reports.
Personal injury — assessment of damages — fracture of tibia with permanent scarring — pain and suffering, loss of amenities, disfigurement — special damages must be proved; reasonable compensation where proof lacking — reliance on comparable awards.
4 June 2021
Court quashed unlawful Electoral Commission appointments for breaching statutory nomination limits and ordered prompt re‑nomination.
Electoral law — Nomination and appointment of Electoral Commission commissioners — Interpretation and enforcement of section 4 of the Electoral Commission (Amendment) Act — Validity of appointments where a party exceeds statutory nominee limit — Locus standi of political party to challenge appointments — Waiver and acquiescence not applicable to constitutional/political rights.
2 June 2021
May 2021
Assessment of damages for amputation injuries, loss of earning capacity calculation, and insurer's policy limit on costs.
Personal injury — below‑knee amputation — assessment of general damages (pain and suffering, loss of amenities, disfigurement); loss of earning capacity where earnings unproven — use of minimum wage and appropriate multiplier; insurer policy limits and whether party‑and‑party costs are included — governed by express policy wording.
31 May 2021
Assessment awarded K4,750,000 for a minor’s road accident injuries; special damages denied for lack of proof.
Personal injury – assessment of damages for a minor – pain and suffering, loss of amenities, disfigurement/incapacitation – requirement of proof for special damages – use of comparable awards and adjustment for currency devaluation.
28 May 2021
Court authorized kinship adoption after finding statutory requirements met and imposed yearly school-reporting for the child’s welfare.
Adoption law – Adoption of Children Act requirements – parental consent – residency – guardian ad litem report – kinship adoption – court-imposed post-adoption reporting condition.
25 May 2021
General denials and inconsistent explanations do not justify setting aside a timely default judgment.
Civil procedure — Default judgment — Setting aside under Order 12 Rule 21 — timely application insufficient without reasonable cause and meritorious defence — general denials and inconsistent explanations inadequate — stay of assessment refused; defence struck out; costs awarded.
25 May 2021
Court continued interlocutory injunction to preserve disputed land status where ownership is triable and damages inadequate.
Interlocutory injunctions — American Cyanamid test — serious question to be tried; adequacy of damages; balance of convenience; ex parte orders and alleged suppression of material facts; procedural requirements for interlocutory applications under Order 10 of the High Court (Civil Procedure) Rules; preservation of status quo in disputed land ownership.
25 May 2021
Whether employees of a state-owned company incorporated under Companies Act are public officers under anti-corruption laws.
Company law – State-owned company (Companies Act s.26) – public body status; Public law – definition of public officer under Corrupt Practices Act and Penal Code; applicability of Public Procurement Act and public-officers asset-declaration obligations; preliminary objection to charges dismissed.
25 May 2021
Court granted leave to judicially review COVID-19 restrictions but dismissed interlocutory injunction for procedural non-compliance.
Administrative law — judicial review — leave to apply where public-health measures affect rights; procedural requirements for interlocutory injunctions; ultra vires and parliamentary oversight of public health rules.
25 May 2021
Claimant hit by vehicle awarded K7.5m for pain, suffering, loss of amenities and disfigurement.
Personal injury — Assessment of damages — Heads: pain and suffering, loss of amenities, disfigurement — Quantum by comparison with authorities — Evidentiary gaps do not necessarily defeat award — Liability settled by consent.
24 May 2021
Court dismissed defendant’s strike-out application, finding contractual claim not plainly displaced by the Public Roads Act and not frivolous.
Civil procedure – strike-out for frivolous/vexatious or abuse of process – inherent jurisdiction; Public Roads Act – statutory compensation procedure and contractor powers; section 21(1) immunity and section 21(2) preservation for negligence; contractual claim versus statutory remedy.
24 May 2021
24 May 2021
Leave for judicial review granted of public body's change to tobacco transport allocation; injunction dismissed for procedural defects.
Administrative law – Judicial review of public body decision on tobacco transport allocations – Legitimate expectation and procedural fairness – Timeliness and sufficient interest – No alternative statutory remedy – Interlocutory injunction dismissed for procedural non-compliance.
21 May 2021
Leave for judicial review granted against transport policy; interlocutory injunction dismissed for procedural defect.
Administrative law – Judicial review of public body's transport policy – Decision of 23 March 2021 reviewable; leave granted; no mandatory alternative remedy; interlocutory injunction dismissed for procedural noncompliance.
21 May 2021
False imprisonment and loss-of-income claims dismissed for lack of proof that the employer procured the arrest.
False imprisonment – whether detention was procured by employer or resulted from independent police investigation; employer’s reporting versus procuring arrest; proof on balance of probabilities for civil damages; entitlement to loss of income; costs in court’s discretion.
20 May 2021
Criminal court dismisses accused's attempts to nullify proceedings, recuse the judge, or obtain a permanent stay for delay.
Judicial tenure/extension – jurisdiction to review – criminal trial not appropriate forum; recusal – fair‑minded and informed observer test; case management and delay – not proof of bias; permanent stay refused.
20 May 2021
18 May 2021
18 May 2021
18 May 2021
Whether a confirming court should enhance a 36‑month sentence for robbery with violence given mitigating factors and comparative sentencing trends.
Criminal law — Confirmation of sentence — Robbery with violence — Sentencing discretion — Mitigating factors (first offender, youth, no weapon, compensation) — Sentencing range 5–10 years — Comparative authorities considered.
18 May 2021
Whether the applicant is a bona fide purchaser and whether the prior consent order remains valid and triable without a full hearing.
Civil procedure – originating summons – procedural noncompliance under new rules (defence, summary judgment/mediation, trial) – triable issues require hearing; Property law – bona fide purchaser for value without notice; Consent orders – binding as judgments; to set aside require fresh action or proper legal cause (fraud/mistake/misrepresentation); Contempt allegation cannot be determined without full hearing.
13 May 2021
12 May 2021
Court maintained 100% care and conduct, reduced instruction fees, and excluded in-house counsel from personally receiving taxed costs.
Costs assessment — care and conduct (100%) — instruction fee reduced to K8,000,000 per counsel — in-house counsel not entitled to receive taxed costs personally — distribution of taxed bill left to parties — objections to specific line items dismissed.
12 May 2021
Assessment of damages for deaths and injuries in a road accident; special damages denied for lack of proof.
Personal injury—assessment of damages; loss of expectation of life; loss of companionship; pain and suffering; loss of amenities; disfigurement; special damages require strict pleading and proof; use of comparative awards and adjustment for currency devaluation.
10 May 2021
Court awarded K5,000,000 in damages for personal injuries, denying unproven special damages and granting leave to appeal.
Personal injury — assessment of damages — pain and suffering, loss of amenities, disfigurement — loss of earnings and earning capacity where pre-accident income unproven — special damages require strict proof — use of comparable awards and adjustment for currency devaluation.
7 May 2021
Assessment awarded K7,750,000 for claimant’s amputation injuries covering pain, amenities, disfigurement, and lost earning capacity.
Personal injury — assessment of damages — pain and suffering; loss of amenities; disfigurement; loss of earning capacity where claimant is self‑employed without documented earnings; need for proof of special damages; reliance on comparative awards and adjustment for currency value.
7 May 2021
Court awarded MK65,000,000 for crop losses, trees, loss of use and consequential agronomical damages, with apportioned liability and leave to appeal.
Assessment of damages – loss of crops and projected profits – business projections admissible but may be discounted for contingencies; Loss of trees and seedlings – proof by oral and corroborative evidence; General damages for deprivation of use – discretionary award; Consequential damages – annual accrual until return of possession; Allocation of liability – erroneous lease by Attorney General.
7 May 2021
Assessment awarded K65,000,000 for lost crops, lost use of land and ongoing agronomical damages, with leave to appeal.
Assessment of damages – proof and quantification of loss of commercial crops and projected income; valuation of lost trees and seedlings; general damages for deprivation of land use; consequential agronomical damages accruing annually; costs and leave to appeal.
7 May 2021
Assessment of damages for destroyed crops and land, annual consequential damages, and State liability for erroneous lease.
Assessment of damages – loss of crops and projected profits – distinction between general and special damages – requirement of proof for special damages – discounting speculative projections for contingencies – loss of use awards – State liability for erroneous lease issuance – consequential damages accruing annually until possession restored.
7 May 2021
Assessment of damages for road‑traffic personal injuries: awards for pain, loss of amenities and disfigurement; no special damages proved.
Motor vehicle accident – Assessment of damages – General damages (pain and suffering) – Loss of amenities of life – Disfigurement – Special damages not proved – Use of comparable awards and adjustment for currency devaluation.
7 May 2021
Court awarded K4,000,000 to the claimant for personal injuries, denying unproven special damages.
Assessment of damages; personal injury—pain and suffering; loss of amenities of life; special damages—proof required; use of comparable awards and adjustment for currency devaluation.
7 May 2021
Assessment of damages against the respondent for medical negligence causing the applicant’s newborn’s death.
Medical negligence – Assessment of damages for death of newborn – Pain and suffering; loss of expectation of life; reimbursement of proven medical and incidental expenses; use of comparable awards and currency value in quantum assessment; unopposed evidence and expert opinion.
7 May 2021
Court taxed applicants’ bill, awarding care and conduct at 70% applied to the total, totalling MWK17,133,187.50.
Civil procedure – assessment of costs – care and conduct allowance – appropriate percentage (70%) and application to total bill; taxation of party-and-party costs; application of prescribed hourly rate (K40,000).
7 May 2021