High Court of Malawi - 2022

238 judgments

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238 judgments
Citation
Judgment date
December 2022
Convictions quashed where prosecution relied on uncorroborated accomplice evidence and improperly authenticated call‑logs.
Criminal law — Dangerous drugs (possession and attempted export) — accomplice evidence and requirement for corroboration — admissibility of co‑accused caution statements as witness evidence under s.175 — computer‑generated call logs and witness competence/authentication.
23 December 2022
9 December 2022
Court confirmed defilement conviction and increased sentence to 40 years due to breach of trust, threats, and HIV transmission.
Criminal law — Defilement: elements and proof; identification evidence; medical corroboration not essential but supportive; sentencing — aggravating factors (breach of trust, threats, HIV transmission) justify substantial enhancement.
6 December 2022
Conviction for defilement upheld and sentence enhanced to 40 years due to serious aggravating factors.
Criminal law – Defilement (s.138(1) Penal Code) – sufficiency of evidence and corroboration of child’s testimony – medical evidence not indispensable – sentencing enhancement – aggravating factors (young victim, planning, force, psychological harm) outweighing first‑offender mitigation.
6 December 2022
Court confirmed robbery convictions, upheld identification evidence, and enhanced custodial sentence to concurrent terms.
Robbery – identification evidence – Turnbull guidelines – confirmation of conviction – sentencing: aggravating factors (mask, group, violence, planning) outweighing youth and first-offender mitigation – sentence enhancement to concurrent terms.
6 December 2022
Non‑therapeutic circumcisions of minors without valid parental/guardian consent constituted battery, breach of duty and violated bodily integrity.
:[
2 December 2022
Proceedings were prejudiced by magistrate conduct amounting to bias and re‑victimization, requiring retrial, victim support and disciplinary/systemic reforms.
Criminal procedure — judicial conduct and impartiality — secondary victimization in sexual‑offence trials — gender stereotyping — retrial ordered; referral to Judicial Service Commission; victim support ordered.
1 December 2022
November 2022
Court granted injunctions, demolition and damages where defendant’s predecessor unlawfully encroached public road and claimant’s land.
Property law – Encroachment on road reserve and adjoining private land – locus standi to sue where private injury shown – public land not susceptible to acquisition by prescription – mandatory and prohibitory injunctions and damages awarded.
30 November 2022
Prosecution evidence was insufficient and unreliable to require the accused to enter a defence; accused acquitted.
Criminal law — no-case-to-answer — sufficiency of prosecution evidence — hearsay and inconsistent witness testimony — unmarked exhibits — failure to establish circumstantial link to crime.
16 November 2022
Court dismissed application to re-enter an appeal; dismissal for non-appearance cannot be revived and no sufficient cause was shown.
Civil procedure — dismissal for non-appearance — Order III r.21(2) — re-entry of appeal — sufficiency of cause — inherent jurisdiction — functus officio — delay and lack of diligence.
10 November 2022
October 2022
Court held instruction fee payable once proceedings commenced, reduced fee and ordered revised costs payable within 14 days.
Costs — Instruction fee — Order 31 Rule 10 — Entitlement to instruction fee once proceedings commence in High Court even if no trial — Court's discretion to reduce quantum of fee.
30 October 2022
Court granted extension to file for judicial review, finding no prejudice or inordinate delay, deferring statutory time‑bar issues to substantive hearing.
Civil procedure – extension of time to seek judicial review – discretionary power under Order 19 r.20(6) – considerations: prejudice to respondent/public, detriment to good administration, and reasonableness of delay; Tax law – limitation/sunset clause (s.125 Taxation Act) raised but not decided at extension stage.
24 October 2022
Court awarded 10% of the judgment plus assessed disbursements, refusing refresher fees for lack of evidence of three‑hour sittings.
Costs — assessment under Subordinate Court Rules Order XXX r 2 and Second Schedule — 10% of judgment debt awarded — refresher fees require continuous court seating of three hours or more and proof — additional heads allowed: attendance, service, disbursements, secretarial, stationery — total assessed MK3,772,260.76.
12 October 2022
Assessment of quantum for unfair dismissal: salary base, mitigation, pension and severance, with a 50% devaluation uplift.
Labour law — assessment of damages for unfair dismissal — appropriate salary base (statutory salary vs overtime) — mitigation of loss — entitlement to statutory employer pension contributions — severance pay calculation — adjustment for currency devaluation — inadmissibility of unpleaded heads of damage.
10 October 2022
Assessment of compensation for unfair dismissal, applying mitigation, statutory minima and accepting uncontroverted applicant evidence.
Employment law – unfair dismissal – assessment of compensation – Section 63(4) & (5) Employment Act – mitigation of loss – severance pay – notice pay – withheld wages – effect of failure to call witnesses.
4 October 2022
Whether the respondent is liable to maintain the children and the appropriate financial and material maintenance order.
Child maintenance – liability to maintain children – assessment under Child Care Protection and Justice Act s.10 – orders for monetary upkeep, school fees, clothing, medical bills, rent contribution, vehicle provision – duration sv. s.15/s.16 – best interests of the child.
4 October 2022
September 2022
Appellants' convictions for unlawful wounding upheld, but 18‑month custodial sentences set aside and immediate release ordered as excessive.
Criminal law – Unlawful wounding (s.241(a)) – proof beyond reasonable doubt – eyewitness credibility; Sentencing – first offenders, ss.339–340 CPE Code – discretion to not suspend; Excessive sentence – appellate reduction and immediate release.
22 September 2022
High Court stayed its proceedings where concurrent subordinate-court action remained unresolved because costs were not agreed, assessed or paid.
Civil procedure – abuse of court process – concurrent proceedings in different courts – withdrawal of subordinate-court action does not conclude proceedings until costs are agreed/assessed/paid – High Court’s inherent jurisdiction to stay proceedings.
19 September 2022
Joinder of an insurer after the two‑year RTA limitation is time‑barred; insurer ordered to pay costs for raising the objection late.
Road Traffic Act s148 – Limitation of direct claims against insurers to two years; s148(1)(c) preserves only proceedings actually commenced against insurer within two years; late joinder of insurer time‑barred; mistake in insurer identity does not extend limitation period; discretion to award costs against successful but unreasonably late objector.
16 September 2022
Claim dismissed with costs where claimant’s eyewitness evidence was discredited and police report was inadmissible hearsay.
Road traffic negligence – duty of care of driver – requirement to prove negligence on balance of probabilities; amendment of pleadings under Order 7 r 23(1); hearsay inadmissibility of police report under Order 17 r 55; evidentiary weight of discredited eyewitness testimony.
16 September 2022
Employer liable for negligence and for breaching statutory duty by failing to provide a safe system of work; damages awarded.
Employer liability – negligence and breach of statutory duties (Occupational Safety, Health and Welfare Act: ss.13, 64) – safe system of work – mechanical appliances – res ipsa loquitur inapplicable – pleading particulars and PPE claims.
16 September 2022
Unmarked roadworks obstruction caused injury; defendant 75% liable, claimant 25% contributorily negligent.
Negligence — roadworks obstruction — duty to warn road users of obstructions — adequacy and persistence of warning measures; contributory negligence for cycling at night without illumination; apportionment of liability; res ipsa loquitur inapplicable.
16 September 2022
Ex parte interlocutory injunction discharged for likely suppression of material facts; balance of convenience favors the respondent.
Land law – interlocutory (ex parte) injunction – duty of full and frank disclosure – suppression of material facts – serious question to be tried – balance of convenience – enforcement notice and alleged unauthorised development under Physical Planning Act.
13 September 2022
Court reversed refusal to forfeit tainted timber, holding forfeiture discretionary, remedial, and not double punishment.
Criminal law — Forest Act s.68, s.74 — Forfeiture of tainted property — "May" denotes judicial discretion — Forfeiture remedial not punitive — Forfeiture may extend to foreign-sourced produce — Third‑party property requires hearing.
12 September 2022
Assessment of damages for negligent medical care causing leg amputation—awards for pain, loss of amenities, and disfigurement, special damages denied.
Damages assessment – medical negligence – amputation – awards for pain and suffering, loss of amenities, disfigurement – refusal of special damages for lack of strict proof – use of comparative awards and inflation adjustments.
11 September 2022
Application to set aside default judgment dismissed for inordinate delay and lack of a bona fide meritorious defence.
Civil procedure — Setting aside default judgment — Order 12 r 21 CPR 2017 — requirement of reasonable cause and meritorious defence — promptness and inordinate delay — vacatur of stay of execution.
5 September 2022
August 2022
A driver’s unsafe left overtaking and failure to stop found negligent; insurer liable, registered owner not.
Negligence – duty of care of drivers – failure to keep proper lookout and unsafe overtaking (left) – standard of proof on balance of probabilities; Motor vehicle collisions – liability of driver and insurer; Evidentiary weight of police/traffic officer reports; Owner liability not established.
30 August 2022
Conviction for trafficking quashed where prosecution failed to prove prohibited means and purpose of exploitation.
Criminal law – Trafficking in persons – Elements: action (e.g. transporting), proscribed means (force, fraud, abuse, payment to obtain consent, etc.) and purpose (exploitation); burden of proof beyond reasonable doubt; failure to prove means and purpose mandates acquittal; appellate rehearing and error where trial court did not separately consider all elements.
30 August 2022
Forfeiture of a vehicle requires evidence linking the owner and an opportunity for the owner to be heard.
Forestry Act s74(1)(f) — forfeiture of vehicle; property rights (Constitution s28) — arbitrary deprivation; presumption of innocence; instrumentality of crime — requirement of direct/systematic use; procedural requirement to hear owner/show cause; appellate setting aside under s353(1)(b) of the Code.
23 August 2022
Short detention during a march amounted to false imprisonment and a reduced award due to claimant’s provocative conduct.
Constitutional right to protest — False imprisonment — Assessment of non-pecuniary damages — Duration and aggravation — Mitigation of punitive damages where claimant’s conduct contributed to the harm.
19 August 2022
16 August 2022
Ex parte permission and stay vacated because claimants lacked locus standi and materially misrepresented their status.
Judicial review — ex parte permission and interim relief — vacatur for lack of locus standi and material non-disclosure; Refugees Act — refugee status determination and effect of Minister's decision; scope of governmental relocation notice (rural v urban); costs awarded.
12 August 2022
Court refused review of respondent’s 700MHz cease-and-desist but granted review of related fine and accounting orders.
Administrative law — Judicial review (permission stage) — arguable case required; Legitimate expectation — temporary licence and notice of competitive reassignment; Spectrum regulation — migration from 700 MHz band 17 to band 28, cease-and-desist, fines and revenue account; Procedural fairness and reasons for administrative action.
12 August 2022
Court refused review of cease-and-desist order due to temporary licence and prior notice, but allowed review of fine and accounts requirement.
Administrative law — Judicial review — Permission stage — Legitimate expectation — Temporary licence and competitive reassignment of spectrum — Reasons for administrative action — Interlocutory injunctions — Wednesbury unreasonableness.
12 August 2022
Employer liable for employee’s burn injuries from sludge due to unsafe system and lack of protective measures.
Negligence – employer’s duty of care and safe system of work; Occupational Safety, Health and Welfare Act – provision of safety instructions and protective clothing; contributory negligence – not established; failure to call material witnesses; assessment of damages ordered.
11 August 2022
Award of K3,500,000 for pain, suffering and loss of amenities; no separate disfigurement award; costs to be assessed.
Personal injury — Assessment of damages — Pain and suffering and loss of amenities — Quantum — Disfigurement — Default judgment — Use of comparable authorities.
11 August 2022
Plaintiff proved some unpaid invoices but failure to traverse limitation plea rendered older claims statute-barred.
Civil debt recovery – unpaid invoices – plea of limitation – Order 18 r.13 deemed admissions – acknowledgement of debt and effect on limitation – assessment before Registrar – interest and costs.
9 August 2022
Court continued injunction restraining purported Leader of Opposition appointment; perjury/suppression allegations dismissed.
Judicial review/interlocutory injunctions – ex parte relief – duty of full and frank disclosure; Political party internal decisions – justiciability and scope of judicial oversight; Constitutional political rights – right of MPs to participate in party processes; Adequacy of damages – non-pecuniary nature of office; Procedural directions – continuation of interlocutory relief pending trial.
8 August 2022
Court reduced claimed personal injury damages and awarded K4,000,000 with costs to be assessed if not agreed.
Personal injury — assessment of general damages — injuries including deep forehead laceration, bruises, deformed/swollen knees and dislocated hip — use of comparable precedents to determine quantum — award reduced from claimed amount to K4,000,000 — costs to be assessed if not agreed.
5 August 2022
4 August 2022
Court awarded damages for 10‑day false imprisonment, dismissed malicious prosecution, and granted loss of business, defamation, and costs.
False imprisonment — quantum for loss of liberty, indignity and mental suffering; duration and conditions considered. Malicious prosecution — requires prosecution determined in claimant’s favour, not proved. Defamation — damages awarded despite limited evidence of reputational harm. Loss of business — discretionary award where financial records absent. Costs — party-and-party on standard basis following default judgment.
4 August 2022
Conviction for attempted suicide confirmed; custodial sentence set aside under s340(1) in favour of immediate release.
Criminal law – Sentencing – Attempted suicide – Custodial sentence for first offender – Section 340(1) CPE Code requires recorded good grounds before imprisonment – High Court review powers under Courts Act ss25–26 and CPE Code s362.
4 August 2022
Assessment of damages for amputation: forearm loss subsumed under pain and suffering and K9,000,000 awarded.
Personal injury — assessment of damages — loss of limb (forearm) treated as part of pain and suffering/disfigurement — viva-voce evidence sufficient where medical report raises hearsay concerns — application of comparable awards principle.
1 August 2022
Court awarded K4,000,000 for pain and suffering and loss of amenities; special damages not proved; order against 2nd defendant.
Personal injury — Assessment of damages — General damages for pain and suffering and loss of amenities — Fracture, shoulder bruises, eye injury — No proof of disfigurement — Special damages not proved — Default judgment; exhaustive assessment.
1 August 2022
Viva-voce evidence can establish serious injury absent X‑rays; claimant awarded MK7,000,000 inclusive, costs to defendants.
Personal injury — proof of fracture — viva-voce evidence acceptable where X‑rays absent — hearsay limits on medical reports — assessment of quantum — comparability of awards.
1 August 2022
July 2022
Cancellation of an industrial rebate without a hearing breached section 43, violated legitimate expectation, and was quashed.
Administrative law – section 43 Constitution – right to lawful and procedurally fair administrative action – legitimate expectation – right to be heard – cancellation of industrial rebate – customs regulations – Wednesbury unreasonableness – certiorari.
28 July 2022
Applicants proved entitlement to 18 months' unpaid salaries; court awarded amounts plus a 25% devaluation uplift, payable within 14 days.
Labour law – assessment of salary arrears after default judgment – burden and standard of proof in assessment proceedings – awarding currency devaluation uplift – proceeding in absentia where service proved.
25 July 2022
Default judgment set aside despite delay because judgment contained unpleaded monetary and leave awards and alleged improper service.
Civil procedure – setting aside default judgment – inordinate delay versus irregularity of judgment (unpleaded quantified awards, improper service) – court’s discretion to revoke judgment obtained by procedural failure.
25 July 2022
The applicant was awarded just and equitable compensation for unfair dismissal, statutory entitlements, and a 25% inflation uplift.
Employment law — unfair dismissal — assessment of compensation under Section 63(4)–(5) Employment Act — severance, gratuity, overtime, accrued leave, notice pay — burden and standard of proof — mitigation of loss — inflation/currency devaluation uplift.
25 July 2022
Matters involving alleged loss of customs, tax and VAT revenue belong in the High Court Revenue Division and must be transferred.
High Court divisions — Revenue Division v Criminal Division — section 6A Courts Act — revenue matters (Customs, Tax, VAT) — transfer of proceedings commenced in wrong Division — judge’s inherent power to transfer — procedural consequences of wrong forum.
25 July 2022