High Court of Malawi - 2022

238 judgments

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238 judgments
Citation
Judgment date
February 2022
Whether section 9’s Preliminary Inquiry follows CP&EC Part VIII, witness presence, authentication, and reconciling treaty obligations.
Extradition — Preliminary Inquiry under section 9 Extradition Act — Part VIII CP&EC applies mutatis mutandis; extradition character: criminal; witness presence — physical preferred but virtual allowed in appropriate cases; evidence taken before foreign competent court under Evidence by Commissions Act effective; authentication governed by section 13 Extradition Act; treaty obligations (pacta sunt servanda) to be respected when possible.
8 February 2022
Preliminary inquiries under the Extradition Act follow Part VIII CP & EC; witnesses’ physical presence is preferred but may be dispensed with under defined procedures.
Extradition law – section 9 Preliminary Inquiry construed as Part VIII CP & EC preliminaries; extradition committal is criminal in nature; Criminal Division has jurisdiction to review committals; witness presence preferred but not absolute—virtual testimony or foreign court examination permissible; authentication governed by section 13 of the Extradition Act and Evidence by Commissions Act.
8 February 2022
An application to reopen a final 2016 disciplinary disbarment was rejected: the High Court had jurisdiction, gave adequate notice, and was functus officio.
Legal practitioners — Disciplinary jurisdiction of High Court under s.21 Legal Education and Legal Practitioners Act — Reasonable opportunity to be heard via national publication and Malawi Law Society involvement — Functus officio and finality of judgments — Abuse of process in reopening final disciplinary orders.
8 February 2022
High Court may review subordinate court decisions, including interlocutory rulings, to protect fair trial rights after late disclosure.
Constitutional and statutory review — High Court supervisory jurisdiction over subordinate courts — Sections 25–28 Courts Act and sections 360–363 Criminal Procedure and Evidence Code — party-initiated and interlocutory review — adjournment and fair trial rights following late disclosure.
8 February 2022
January 2022
Claimant awarded K20,000,000 for false imprisonment, defamation, malicious prosecution and assault.
Damages assessment — false imprisonment (21 days): rejection of hourly formula; awards for defamation, malicious prosecution and assault and battery; reliance on comparable Malawian authorities; defendant absent at assessment.
31 January 2022
Embargo and factory closure under s149 were unlawful absent proceedings; search warrant did not justify closure.
Customs & Excise Act s149 (embargo) — scope and limits; s15(1)(a) — search warrants and securing premises; corporate separate legal personality; procedural fairness/hearing; embargo invalid absent connected proceedings.
28 January 2022
A registrar lacks jurisdiction to grant post-judgment amendments; such applications must be determined by the judge seized of the case.
Civil procedure – Amendment of statement of case – Order 7 r 23 – Permission required after closure – Registrar’s jurisdiction under Courts Act and CPR – Order 25 limits Registrar’s automatic powers – Post-judgment/amendment at assessment stage must be determined by the Judge.
28 January 2022
Court granted interlocutory injunction preventing disposal of seized vehicles where ownership and legality of seizure were triable issues.
Judicial review – Interlocutory injunction – Application of American Cyanamid test (serious question to be tried; damages inadequate; balance of convenience) – Seizure of property during searches – Ownership disputes and alleged connection to criminal proceedings – Preservation of status quo pending trial.
28 January 2022
The claimant (DPP) may bring civil preservation proceedings under the FCA; ex parte preservation orders are constitutionally permissible.
Constitutional interpretation — purposive and contextual approach; Financial Crimes Act — competent authority; DPP's locus to institute civil preservation proceedings; Ex parte preservation orders — interim in rem relief to secure tainted property; Compatibility of FCA preservation regime with rights to fair hearing, presumption of innocence, property and dignity; Retrospectivity of non-penal statutory provisions.
26 January 2022
Appellants' custodial sentences for organised forest destruction and squatting upheld as aggravating factors outweighed mitigation.
Criminal law – Sentencing – Forestry offences (destruction of forest produce, squatting) – First offender and guilty plea as mitigating factors – Option of fine and suspended sentences – Group commission, premeditation and injuries to law enforcement as aggravating factors – Sentences upheld.
26 January 2022
Court declared a lease void as unlawfully depriving clan members of customary land and ordered its cancellation.
Customary land — Lease procured without clan consultation — Unlawful deprivation of property — Section 28 Constitution — Transaction void — Order to cancel lease — Costs against lessee.
25 January 2022
Unlawful arrests without reasonable suspicion caused false imprisonment, reputational harm and business loss; malicious prosecution claim failed.
Constitutional and common-law protections of personal liberty — arrest and detention; False imprisonment — requirement of reasonable suspicion and informing arrested persons of reasons; Malicious prosecution — requirement of termination in favour and absence of probable cause; Defamation — publication and reputational injury arising from state-instigated arrests and resultant media coverage; Loss of business — damages for confiscation and non-use of business equipment.
25 January 2022
Appellate court will not overturn a trial court’s land ownership finding absent demonstrable misdirection, prejudice, or supporting evidence.
Land law – ownership dispute over customary/communal land – mkamwini’s capacity to own land – appellate review of factual findings – requirement to show misdirection or prejudice – unsubstantiated allegations of corruption and procedural irregularity insufficient to overturn judgment.
24 January 2022
On the balance of probabilities the claimant’s research was plagiarised; university lawfully withheld the degree but claimant may rewrite and resubmit.
Academic misconduct – Plagiarism – University disciplinary powers under Students' Handbook – Burden of proof on balance of probabilities – Withdrawal or withholding of degree – Right to education and permissible limitations.
24 January 2022
Estate duty must be assessed under the schedule in force at the deceased's date of death, not later amendments.
Estate duty — applicable rate determined by Schedule in force at deceased's date of death — amendments to Estate Duty Act not retrospective — valuation for estate duty at time of death — requirement for fresh assessment by Estate Duty Commissioner.
21 January 2022
Court refused permission for judicial review of recall/shipping arrangements, finding damages and alternative remedies adequate, and dismissed stay.
Judicial review — recall of diplomats and shipping arrangements — legitimate expectation, Wednesbury unreasonableness, bad faith — adequacy of damages and alternative remedies — stay of administrative decision.
20 January 2022
Claimant awarded policy-limit damages for pain, suffering, loss of amenities and disfigurement following a vehicle rollover.
Motor vehicle accident – assessment of damages – pain and suffering; loss of amenities; disfigurement – consent order limiting liability to policy limit – award of policy limit balance and costs.
19 January 2022
An acquittal alone does not establish malicious prosecution; claimant must prove lack of probable cause and malice.
Malicious prosecution — elements (initiation, absence of reasonable and probable cause, malice, favourable termination) — acquittal alone insufficient to prove malice or lack of probable cause — burden of proof on claimant.
19 January 2022
An acquittal does not prove malicious prosecution absent proof of lack of reasonable cause and malice.
Malicious prosecution — elements: initiation, reasonable and probable cause, malice, termination in favour — acquittal alone insufficient where prosecution established prima facie case — burden of proof on claimant.
19 January 2022
Court imposed 30 years’ imprisonment for rape by a police officer on duty, emphasizing breach of trust and serious aggravating factors.
Criminal law – Sentencing in rape cases – aggravating factors: police officer on duty, breach of position of trust, commission within police station, repeated assaults, victim youth – mitigation: first offender – application of defilement sentencing guideline to rape – absence of medical report not fatal to finding of harm.
18 January 2022
The accused, a police officer on duty, received 30 years' imprisonment for raping a detainee at a police station.
Criminal law — Rape — Sentencing — Position of trust and commission while on duty at police station as aggravating factors — Repeated sexual assaults and detention — Absence of medical report not fatal where credible testimonial evidence of harm exists — Custodial sentence appropriate.
18 January 2022
Application for judicial review dismissed for lack of proper parties, locus standi and suppression of material facts.
Judicial review — proper parties and mode of commencement — locus standi (sufficient interest) — prematurity and hypothetical claims — suppression/misrepresentation of material facts — international instruments and domestic enforceability (section 211).
13 January 2022
Leave for judicial review and interim relief refused: wrong defendants, lack of locus standi, premature challenge and material non-disclosure.
Judicial review — proper parties and joinder — locus standi (sufficient interest) — ripeness of administrative action — suppression/misrepresentation of material facts — refusal of leave and interim relief; costs awarded.
13 January 2022
Confessions admissible but not binding on co‑accused absent adoption; two acquitted, three ordered to enter defence.
Criminal law – prima facie case at no-case stage – section 254 CP&EC; Confessions – admissibility and retraction – section 176 CP&EC; Confession against co‑accused – adoption required under s176(2); Proof of death – recovery and forensic identification of human bones; Charges – murder, extraction of human tissue, trafficking in persons.
12 January 2022
An automatic stay under Order 35 r.15 applied; the defendant’s strike-out application was improperly brought without vacating the stay.
Civil procedure — Order 35 r.15 automatic stay of existing proceedings not brought before Court within six months of Rules' commencement; requirement to apply to vacate stay under r.15(2); non-compliance remedies under Order 2 r.3; strike-out application invalid if brought during automatic stay.
11 January 2022
Insurer not liable absent proof of a valid policy; claimant awarded costs due to insurer's withholding of vital information.
:[
11 January 2022
Applicant on prolonged pre-trial remand granted bail where prosecution did not oppose and custody limits had elapsed.
Bail pending trial – interests of justice – Bail Guidelines Act factors (flight risk, witness interference, danger to community, public order) – burden on State to justify continued detention – prolonged pre-trial remand – conditional bail and directions to prosecute.
6 January 2022
6 January 2022
Bail granted to the applicant after prolonged pre-trial detention and State’s non-opposition; trial to be expedited.
Bail — prolonged pre-trial detention and expired custody time limit — Bail Guidelines Act factors — burden on State to justify continued detention — conditional bail and direction to expedite trial.
6 January 2022
Applicant on prolonged remand granted bail where State did not oppose and no interests of justice weighed against release.
Bail pending trial — constitutional right (s42(2)(e)) subject to interests of justice — Bail Guidelines Act 2000 factors (evasion, witness/evidence interference, danger to community, public order) — burden on State to justify detention — court’s independent duty to weigh circumstances — prolonged remand as factor supporting bail.
6 January 2022
6 January 2022
Applicant granted bail after prolonged remand; court weighed Bail Guidelines Act factors and ordered expedited trial steps.
Bail — prolonged pre-trial detention — Bail Guidelines Act 2000 — interests of justice — burden on State to justify continued detention — conditions of bail — court-ordered expedition of preliminary steps.
6 January 2022
Applicant detained over two years granted bail where prosecution did not oppose and interests of justice favoured release.
Bail pending trial — prolonged pre-trial detention; Bail Guidelines Act 2000 factors (flight, witness interference, danger, public order); burden on prosecution to justify continued detention; court's duty to weigh personal circumstances even if prosecution does not oppose bail; directions to expedite trial.
6 January 2022
The applicant's prolonged pre-trial detention warranted bail pending trial, subject to conditions and expedited committal.
Bail — constitutional right to bail (section 42(2)(e)) — Bail Guidelines Act 2000 — interests of justice — prolonged pre-trial detention — burden on State to oppose bail — court's independent duty to weigh personal circumstances — conditions and directions to expedite trial.
6 January 2022
Courts granted bail where statutory pre-trial custody limits had been exceeded or were imminent and the State did not oppose, imposing protective conditions.
Bail pending trial — constitutional right subject to interests of justice — expiry/prolonged pre-trial custody limits — prosecution non-objection — appropriate bail conditions and reporting — court directions for committal/disclosure and trial timetable.
6 January 2022
Courts granted bail where investigations were complete or remand prolonged, imposing conditions to protect the interests of justice.
Criminal procedure – Bail pending trial – Constitutional right to bail limited by interests of justice – Effect of completed investigations and State non‑opposition – Prolonged remand and expiry of pre‑trial custody limits – Conditions to prevent flight, witness interference and evidence tampering.
6 January 2022
Applicant on prolonged remand for alleged murder granted bail where State did not justify continued detention; trial steps ordered.
Criminal law – Bail – Right to bail under section 42(2)(e) of the Constitution – Bail Guidelines Act factors (evasion, witness interference, danger to community, public order) – Burden on State to justify detention – Prolonged remand/expired pre-trial custody – Bail granted with conditions; directions for trial.
6 January 2022
Court stayed a hospital arrest, finding it unlawful and unconscionable, and transferred the judicial review for urgent inter partes hearing.
Judicial review – prosecutorial/investigative discretion – abuse of process – hospital arrest – violation of constitutional arrest rights (s42) and Criminal Procedure provisions (s20A) – interim stay and transfer for inter partes hearing.
1 January 2022