High Court of Malawi - 2022 June

25 judgments

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25 judgments
Citation
Judgment date
June 2022
Defendants held in contempt for disobeying an injunction, but court declined to convict due to disputed title.
Contempt of court – interlocutory injunction – obedience to court orders until discharged – disputed title and letters of administration – discretion not to convict.
30 June 2022
Employment-related claims must be commenced in the Industrial Relations Court; the High Court should decline first-instance jurisdiction.
Constitutional and statutory jurisdiction — Industrial Relations Court as first-instance forum for employment disputes — section 110(2) Constitution; Labour Relations Act s64 — transfer of employment claims — High Court declining jurisdiction where specialised court exists.
30 June 2022
Claimant failed to prove bus driver's negligence; collision held caused by truck driver veering to avoid a cyclist, claim dismissed.
'Negligence' – duty of care and breach; burden and standard of proof in civil cases; causation in road traffic collisions; res ipsa loquitur – inapplicable where claimant's evidence is inconsistent; submission of no case to answer in civil proceedings; costs—court's discretion.
27 June 2022
The claimant was awarded K7,028,000 for pain, loss of amenities, disfigurement and special damages after a road accident.
Personal injury — assessment of damages — fractures of tibia and fibula and facial bruising — non‑pecuniary heads: pain and suffering, loss of amenities, disfigurement — reliance on comparative awards — special damages for report costs — costs awarded.
24 June 2022
24 June 2022
Claimant awarded K7,000,000 for pain, loss of amenities and disfigurement from a workplace hand injury; special damages denied.
Personal injury — Workplace accident — Assessment of damages — Non-pecuniary damages: pain and suffering, loss of amenities, disfigurement — Quantum awarded K7,000,000 — Special damages not proved — Costs awarded.
24 June 2022
Minor injured in road accident awarded K14,013,500 for amputation, pain, loss of amenities, and disfigurement.
Personal injury — Road traffic accident — Amputation and multiple fractures — Assessment of damages by Registrar — Awards for pain and suffering, loss of amenities and disfigurement — Special damages for police and medical reports — Payment into trust account for minor.
24 June 2022
Court awarded K4,000,000 for death of an 11‑year‑old, using comparable awards and reasonable future probabilities for dependency.
Damages — Wrongful death of a child — Loss of expectation of life guided by comparable awards; Loss of dependency for non‑working child assessed by reasonable future probabilities (not multiplier–multiplicand).
24 June 2022
Assessment of non-pecuniary damages for three injured claimants; psychological effects not awarded without evidence.
Damages assessment — non-pecuniary losses (pain and suffering, loss of amenities, disfigurement) — need for evidence to prove psychological injury — awards to minors and trustee account for guardian access.
24 June 2022
Claimant awarded MK4,810,000 for proven minor head and limb injuries; traumatic brain injury claim rejected.
Personal injury — Assessment of quantum — Pain and suffering, loss of amenities and disfigurement — Loss of earnings and earning capacity — Insufficiency of evidence for traumatic brain injury and undocumented business income — Use of comparable awards.
23 June 2022
A defendant’s preliminary objection was dismissed for failing to follow court direction to pursue an inter-partes challenge to a consent order.
Civil procedure – consent order alleged entered by mistake – ex parte application to stay or set aside vs inter-partes procedure – preliminary objection at assessment hearing improper where party failed to follow court direction – dismissal with costs.
23 June 2022
High Court set aside magistrate's costs order against counsel, holding no statutory authority for such costs on adjournment.
High Court supervisory jurisdiction — Sections 25 and 26 Courts Act; s360 Criminal Procedure and Evidence Code — power to call records and review subordinate courts; Magistrates' power to award costs — statutory basis required; Criminal proceedings — presumption against awarding costs; Adjournment — discretionary but cannot found costs order absent statutory authority; Section 142 CP&E Code — costs permissible on conviction/acquittal or where private prosecutor had no reasonable grounds.
22 June 2022
Driver negligent; deceased partly contributory — liability apportioned 70/30 and insurer liable up to policy limit.
Road traffic accident — Driver negligence for failing to slow/stop — Eyewitness credibility — Contributory negligence by pedestrian — Apportionment of liability (70%/30%) — Insurer liability subject to policy limit (s.148(1) Road Traffic Act).
22 June 2022
Court awarded K2,000,000 for expectation and K2,000,000 for dependency after an 11‑year‑old's death; multiplier method rejected for non‑earning child.
Personal injury — fatal road accident — assessment of damages — loss of expectation of life — loss of dependency — child of non‑working age — comparable awards preferred; multiplier‑multiplicand method inappropriate for non‑earning child.
22 June 2022
Whether criminal libel under section 200 unreasonably restricts freedom of expression and warrants certification and a stay.
Constitutional law — Freedom of expression — Criminal libel (s.200 Penal Code) — Section 35 and limitation test under s.44 Constitution — ICCPR art.19 and ACHPR art.9(2) — de Morais v Angola; Lohe Issa Konate v Burkina Faso — Referral to Chief Justice under s.9(3) Courts Act — High Court inherent jurisdiction — Civil Procedure Rules O.19 limited to civil matters — Stay of subordinate court proceedings.
20 June 2022
Court enhanced defilement sentence to 18 years, finding aggravating factors outweighed mitigating circumstances.
Criminal law – Defilement – Sentencing and sentence enhancement – Aggravating factors (victim’s age, premeditation, prevalence of offence, not‑guilty plea) vs mitigating factors (youth, first offender) – Consent not established; deterrence and protection of girl child.
20 June 2022
Claimant failed to prove driver negligence; collision likely occurred while claimant was joining the main road.
Negligence — duty of care — burden of proof on balance of probabilities — point of impact disputed — evidential weight of police report and fine.
18 June 2022
The defendant held liable for breach of statutory safety duty after unguarded conveyor laces caught the plaintiff's jacket.
Occupational safety — employer's statutory duty and negligence — guarding of machinery (conveyor laces) — credibility of post-accident investigations; failure to call material witnesses.
17 June 2022
Court vacated leave and interim orders: parliamentary seating and shadow-cabinet appointments are political, non-justiciable matters; claimant to pay costs.
Parliamentary privilege and separation of powers – Justiciability – Allocation/reservation of seats and formation of shadow cabinets seen as political/internal matters not amenable to judicial review absent clear constitutional issue – Speaker’s discretion under Standing Order 39 – Non-exhaustion of internal remedies and suppression of material facts bars equitable relief.
16 June 2022
No arguable appeal existed against tax assessments; statutory time and form requirements were not met, so judicial review and interlocutory relief were refused.
Tax law — judicial review — validity of appeal against tax assessment — strict compliance with statutory time limits and form for appeals under Value Added Tax Act, Taxation Act and Customs and Excise Act — enforcement (warrant of distress, embargo) where no valid appeal.
16 June 2022
Application to amend notice of appeal refused because proposed particulars would breach the rule requiring concise, non‑argumentative grounds.
Civil procedure — Amendment of notice of appeal — Order 111 rules 2(2) and 2(3) — Particulars of misdirection or error of law must be stated but grounds must remain concise and non‑argumentative — Application to add full particulars refused — Costs awarded.
15 June 2022
Summary judgment granted for claimant’s possession and rental claims where the uncontested will bequeathed the property and defendant had no arguable defence.
Succession law – validity and effect of will – beneficiary entitled to property; Summary judgment – no arguable defence; Possession and mesne profits; Executor/trustee status versus beneficiary rights; Matrimonial property claims irrelevant where property belongs to third‑party testator.
10 June 2022
Summary judgment for possession and mesne profits where the house was bequeathed under an uncontested will and defendant had no arguable defence.
Succession/estate law – testamentary bequest – property bequeathed under an uncontested will; Summary judgment – Order 12 – absence of arguable defence and no triable issue; Matrimonial property/contribution claims distinguished from testamentary rights; Possession and mesne profits (rentals) assessed by Registrar.
10 June 2022
Claimant failed to prove employer negligence under common law and statutory safety duties; defendant nevertheless ordered to pay costs for delays.
Occupational safety — Employer duty to provide safe plant and systems, guarding and training — Negligence — Burden of proof on balance of probabilities — Insufficient, inconsistent evidence — Costs awarded for dilatory conduct.
3 June 2022
A post-judgment application to construe an insurer’s liability for costs was dismissed because no costs were ordered and the court was functus officio.
Civil procedure — Agreement-based judgment for negligence — Construction of insurance policy — Whether insurer liable for costs in addition to damages — Finality of judgment — Functus officio — Post-judgment applications.
3 June 2022