High Court of Malawi - 2022

238 judgments

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238 judgments
Citation
Judgment date
May 2022
Lower court's distribution of matrimonial property without a hearing was irregular; High Court set aside the order and ordered retrial.
Matrimonial property — Distribution requires hearing and evidence — Necessity of parties testing each other’s evidence — Courts Act (s26, s28) supervisory review — Retrial ordered — Preservation of property pending retrial.
27 May 2022
Prolonged unexplained pre-trial detention and the State's failure to comply with court directions justified bail with conditions.
Criminal procedure – Bail pending trial – Prolonged pre-trial detention and State's unexplained failure to comply with court directions – Change of circumstances justifying bail – Conditions of release.
27 May 2022
The applicant failed to prove joint ownership or beneficial interest; neither disputed asset qualified as matrimonial property.
Matrimonial property — Joint ownership — Intention and contribution test (Sikwese v Banda) — Beneficial interest — Registration/insurance not conclusive — Credibility of witnesses in property claims
27 May 2022
Claimant failed to prove driver’s negligence on the balance of probabilities; claim dismissed; parties to bear their own costs.
Motor-vehicle negligence — cyclist injury — burden of proof on balance of probabilities — credibility of witnesses — limited weight of police opinion — impact on vehicle side suggests cyclist swerved into truck.
26 May 2022
Minister acted without statutory authority and breached right to fair administrative action; his decision and the lessor's action were quashed.
Administrative law — Judicial review — Ministerial powers under Statutory Bodies (Control of Contracts) Act — Scope of "contract" — Jurisdictional limit; Natural justice — Right to hearing and reasons — Section 43 Constitution; Invalidity and quashing of administrative decisions; Property rights affected by administrative action.
26 May 2022
A High Court judge may lawfully continue to exercise subordinate court powers and preside over an ongoing magistrates’ trial after elevation.
Courts Act s5A – Powers of High Court judges to exercise subordinate court jurisdiction; Criminal Procedure & Evidence Code s360 – High Court review of subordinate court records; Supervisory jurisdiction under Courts Act s26(1) to be exercised sparingly; Professional conduct – baseless allegations of judicial personal interest.
25 May 2022
Bail denied pending trial for alleged murder due to flight risk given offence seriousness, case strength, and inconsistent account.
Bail — Murder charge — Risk of absconding — Bail Guidelines Act factors: seriousness, strength of case, likely sentence, ties and travel — Conflicting accounts and manner of arrest — Speedy trial directions.
23 May 2022
Assessment of personal injury damages: separate awards for pain, loss of amenities, disfigurement; hearsay objection not entertained.
Personal injury — assessment of damages — heads: pain and suffering, loss of amenities, disfigurement — hearsay objection at quantum stage — separate assessment of damage heads.
20 May 2022
Claimant with Minister-granted lease entitled to injunction and damages for defendant's trespass; alleged right of way and fraud claims dismissed.
Public land — Minister-granted lease — Trespass to land — Public road and right of way — Right of way of necessity — Burden and weight of evidence; refusal to be cross-examined — Counterclaim alleging fraudulent acquisition of lease dismissed.
20 May 2022
Assessment of non‑pecuniary damages for amputation, pain and reduced capacity; award of K5,500,000 plus costs.
Personal injury – Assessment of damages – Default judgment – Non‑pecuniary damages: pain and suffering, loss of amenities (incapacity), disfigurement – Use of precedents to fix quantum – Award of costs.
20 May 2022
Assessment of damages for unlawful arrest, malicious prosecution, defamation and assault by police against the State.
Tort — False imprisonment; Malicious prosecution; Defamation; Assessment of non-pecuniary damages; Vicarious liability of State for actions of police; Special damages for medical reports.
20 May 2022
Claim dismissed: no proved year-long written contract, insufficient proof of crop loss, and defamation not established.
Contract formation – requirement of signed agreement and offer/acceptance; implied contract by conduct; proof of loss in crop claims – need for reliable estimation evidence; defamation – publication, justification, and need to prove reputational harm or actionable imputation.
20 May 2022
Default judgment set aside where defendants showed reasonable excuse for delay and an arguable customary‑law defence.
Default judgment – setting aside – Order 12 r.21 – delay explanation – meritorious defence; Customary land disputes – Customary Land Act 2016 – non‑operational tribunals – High Court original jurisdiction.
20 May 2022
Assessment awards K3,000,000 for pain and suffering, K1,000,000 for loss of amenities, K300,000 for disfigurement; special damages denied.
Personal injury – assessment of damages – fractured jaw, loose tooth, cut and bruises – awards for pain and suffering, loss of amenities and disfigurement – failure to prove special damages – insurer liability subject to policy limit.
20 May 2022
Assessment of damages for severe personal injuries, determining quantum and rejecting unproved special damages.
Personal injury — Assessment of damages — Pain and suffering, loss of amenities, disfigurement, loss of earning capacity — Special damages must be pleaded and strictly proved — Global award where claimant not yet earning — Assessment in absence of insurer after service.
20 May 2022
Sentencing for repeated defilement of a nine‑year‑old by her stepfather increased from 21 to 40 years' imprisonment.
Criminal law – Defilement of a child – Sentencing – Aggravating factors: guardian/stepfather relationship, repeated offences, victim age (nine), physical injury – Manifestly inadequate sentence increased from 21 to 40 years – Prosecutorial charging practices.
18 May 2022
Conviction quashed where conflicting evidence, inadequate credibility findings and improper use of court-called witness created reasonable doubt.
Criminal law — Evidence and credibility — Conflicting witness accounts; duty to state reasons for credibility findings — Court-initiated witnesses under s.201 — Private arrest and reasonable use of force (ss.33,20 Criminal Procedure and Evidence Code) — Acquittal for reasonable doubt.
18 May 2022
Consent induced by fraudulent medical pretence vitiates consent; conviction confirmed and sentence increased for breach of trust.
Criminal law — Rape — Consent vitiated by fraudulent medical pretence; position of trust; aggravating factors; sentence enhancement.
18 May 2022
Assessment of damages for amputation of fingers: awards for non-pecuniary loss and loss of earning capacity; no past earnings award due to lack of proof.
Personal injury — workplace amputation of fingers — assessment of damages for pain and suffering, loss of amenities, disfigurement and loss of earning capacity — use of minimum wage and 10-year multiplicand — no award for unproven past earnings — assessment in default.
13 May 2022
Sale of imported vehicle without the statutorily required gazetted notice was unlawful; claimant entitled only to vehicle value under s154(2).
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12 May 2022
Registrar awards K4,231,400 costs including K1,000,000 instruction fee and declines to decide insurer's liability for costs due to lack of jurisdiction.
Civil procedure – assessment of party-and-party costs – instruction fees payable under Order 31 rule 10(1) – assessment amount set – registrar lacks jurisdiction to interpret or vary a judge’s prior order as to insurer’s liability for costs.
11 May 2022
Court rejects death penalty and imposes long concurrent prison terms for murder, tissue extraction and aggravated trafficking of an albino victim.
Sentencing — death penalty inappropriate under constitutional prohibition of cruel, inhuman or degrading punishment; offences against persons with albinism — premeditation, betrayal of trust, dismemberment and trafficking warrant very severe custodial sentences; extraction of human tissue (s.224A) and aggravated trafficking may attract life‑term severity; first‑offender status and age are mitigating but can be outweighed by aggravating circumstances.
11 May 2022
Accused convicted of murder, extraction of human tissue and trafficking of a person with albinism based on confessions and corroborative circumstantial evidence.
Criminal law – Murder (malice aforethought); Extraction of human tissue – unlawful removal and purpose; Trafficking in persons – obtaining by deception for exploitation; Admissibility and weight of retracted confessions and voluntary video narration; Circumstantial evidence and alibi.
9 May 2022
Failure to exhaust available administrative remedies (payment plan) bars judicial review of a tax demand without a pre‑action hearing.
Tax law – ‘pay now, argue later’ (section 105 Taxation Act); administrative law – pre‑action hearing, Wednesbury unreasonableness; exhaustion of alternative remedies; right to fair administrative action (section 43 Constitution).
6 May 2022
Whether an industrial court may reinstate an employee ex parte and whether such decisions are subject to judicial review.
Judicial review — amenability of lower court decisions; interim relief — ex parte applications; Industrial Relations Court Procedure Rule 25(1)(m)(i); reinstatement as final remedy under section 63 Employment Act; ultra vires/Wednesbury review.
6 May 2022
An educational institution not shown to operate commercially is entitled to full statutory remission; council must refund rates collected since 2017.
Local Government Act s83(1)(e) – remission of rates for educational institutions not operating commercially; valuation roll – omission of 'full remission' does not defeat statutory remission; s76 objection provisions inapplicable to remission entitlement; onus on council to prove commerciality; recovery of money paid ultra vires as money had and received; costs – each party to bear own costs.
4 May 2022
Court granted bail pending trial where no evidence of flight risk, witness interference, or danger to the public was shown.
Criminal procedure – Bail pending trial – Application under Bail Guidelines Act – Considerations: risk of evasion; witness interference; destruction of evidence; danger to public; balancing accused’s personal circumstances against interests of justice – remand duration.
4 May 2022
April 2022
Court imposed life for murder but 25-year terms for tissue extraction and trafficking despite aggravating circumstances.
Criminal law – Sentencing for murder, extraction of human tissue and trafficking in persons – aggravated circumstances (victim's age, albinism, relative involvement, purpose of body-part removal) – worst-offender/death-penalty test – mitigation (first offender, confession, cooperation) – discretionary imposition of life versus fixed-term sentences.
28 April 2022
Forfeiture under section 168 is limited to specified offences; convictions affirmed and matter remitted for resentencing.
Criminal law – Road Traffic Act – Forfeiture of vehicle under section 168 – Applicability limited to offences under section 83 or regulations under s.181(1)(d),(i),(n),(q).; Criminal procedure – Plea of guilty – omission to cite penalty section (s.167) – not fatal if no failure of justice; Sentencing – obligation to sentence on each count before ordering ancillary relief.
27 April 2022
Convictions for unlicensed, uninsured and unregistered motorcycle upheld; forfeiture under s.168 set aside as inapplicable.
Road Traffic Act — forfeiture under s.168 — limited to convictions under s.167(1) as read with s.83 or regulations under s.181(1)(d),(l),(q) — forfeiture unavailable for offences under s.18, s.141, s.11; Conviction on plea; sentencing irregularity — failure to sentence on each count; omission to cite penalty section curable.
27 April 2022
Appellate court upholds magistrate’s revocation of bail where deliberate delays and flight risk justified remand; orders speedy trial.
Criminal procedure – Bail revocation – Interests of justice – Flight risk and deliberate delays in proceedings – Seriousness of offence (life/death sentence) as factor justifying remand.
27 April 2022
Confirmation of 11‑year sentence for adult convicted of defilement of a 15‑year‑old; potential abduction and multiple counts noted.
Criminal law – Defilement (s.138(1) Penal Code) – Abduction (s.136 Penal Code) – Charging all relevant offences and separate counts for multiple occasions – Late guilty plea – Confirmation of sentence.
26 April 2022
Court confirmed burglary conviction where property was removed through an opened window despite entry via an open door.
Criminal law – Burglary vs theft – Breaking requirement under s301 Penal Code – Entry through open door but removal through opened window constitutes breaking out – Sentence confirmation on review.
26 April 2022
Confirmation court increased sentence for aggravated robbery due to weapon use, multiple assailants, and serious wounds.
Criminal law – Aggravated robbery – Sentencing – Use of dangerous weapon and acting in company – Wounding – Confirmation proceedings – Court may increase an inadequate sentence.
26 April 2022
26 April 2022
Lower court’s reliance on respondent’s Portuguese documents without translation warranted remittal for further evidence.
Evidence — foreign-language documents — requirement for translation/expert explanation before acceptance; Civil appeal — rehearing and remittal for further evidence; Property — interim preservation of disputed chattel; Documentary discrepancies — model, chassis and engine identification.
22 April 2022
High Court increased concurrent prison terms for identity-document loan fraud, finding magistrate’s sentences manifestly inadequate.
Criminal law – Forgery – Uttering a false document – Obtaining credit by false pretences – Use of another’s national identity card – Sentencing – Manifestly inadequate sentence – Aggravating factors (premeditation, victim loss, lack of remorse).
22 April 2022
Whether the prosecution proved causation and malice for murder; insufficient evidence and inadmissible postmortem hearsay led to acquittal.
Criminal law – Murder – Prima facie case to answer under s.254 CP&EC – Causation and substantial/operating cause – Malice aforethought – Inadmissibility of hearsay where postmortem report not tendered – Application of R v Smith/Cheshire principles.
22 April 2022
Court set aside provisional interlocutory injunction and declared documents filed by an unlicensed practitioner nullity.
Legal practice licence — Legal Education and Legal Practitioners Act — validity of documents filed by an unlicensed practitioner — nullity of steps — interlocutory injunction criteria (serious question, inadequacy of damages, balance of convenience) — inherent jurisdiction — referral for disciplinary action.
21 April 2022
Documents filed by the respondents' unlicensed counsel were declared nullities and the applicant’s provisional injunction was set aside.
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21 April 2022
Assessment of damages cannot proceed absent a judge's formal order terminating mediation and directing assessment.
Civil procedure – mediation – assessment of damages – Registrar's powers exercisable subject to judge's directions – requirement of formal order terminating mediation before assessment – insurer policy limits and apportionment to be determined in main judgment.
20 April 2022
Oversight or negligence by counsel does not justify setting aside a default judgment absent leave to file out of time.
Default judgment – Application to set aside – Service admitted – Failure to file defence within prescribed time – Oversight/negligence by counsel insufficient – No application for leave to file out of time – Assessment of damages ordered.
19 April 2022
Assessment of unfair dismissal, overtime and severance; court applied Employment Act principles and awarded specified sums.
Employment law – unfair dismissal – assessment of compensation under s63(4)–(5) Employment Act – overtime pay under s39 – severance under s35 – mitigation of loss – deduction of prior payments.
19 April 2022
Application to set aside default judgment refused for inordinate delay; matter to proceed to damages assessment.
Civil procedure – Setting aside default judgment – Inordinate delay – Service on legal representative – Alleged missing court file – Negligence of counsel does not excuse prejudice to the opposing party.
19 April 2022
Application to set aside default judgment refused for inordinate delay and inadequate justification for non-attendance.
Civil procedure — setting aside default judgment — inordinate delay — service on legal representatives — negligence of counsel and missing court file — restoration of struck-out defence.
19 April 2022
Procedurally defective late appeal dismissed; lower court's property and maintenance orders upheld; variation must be sought in lower court.
Civil procedure – appeal from subordinate court – requirement for notice of appeal and leave to appeal out of time; Matrimonial property – distribution of matrimonial home; Maintenance – arrears, contempt and variation procedure under Child Care Protection and Justice Act.
13 April 2022
Conviction for harmful cultural practices quashed where charge particulars, plea-taking and supporting facts failed to establish essential elements.
Criminal law — Harmful cultural practices (s80, s83 CCPJA) — Sufficiency of particulars — Plea-taking requirements (s251 CP&EC) — Necessity of proving elements and nexus to harm — Defective pleas fatal — Conviction quashed; sentence set aside — Retrial declined.
11 April 2022
DPP‑appointed ACB officers may prosecute offences beyond the Corrupt Practices Act if validly authorised.
Corrupt Practices Act; appointment of public prosecutors; Director of Public Prosecutions; Criminal Procedure and Evidence Code s79; ACB power to prosecute non‑corruption offences; statutory interpretation of s10(1)(f).
7 April 2022
First accused convicted of murder, unlawful extraction of human tissue and trafficking; two co-accused acquitted for insufficient evidence.
Criminal law – murder, mutilation and trafficking in persons; admissibility and corroboration of retracted confession; confession not admissible against co‑accused unless adopted; circumstantial evidence and identification of human remains.
7 April 2022
Eyewitness evidence established driver negligence; owner and insurer vicariously liable, police report disregarded for lack of author’s testimony.
Motor vehicle negligence – duty of care of driver – credibility of eyewitness evidence – balance of probabilities – vicarious liability of owner and insurer – inadmissibility/weight of police report where author absent – contributory negligence pleaded.
6 April 2022