High Court of Malawi - 2023

105 judgments

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105 judgments
Citation
Judgment date
July 2023
Seasonal cultivation without exclusive possession and intention does not establish adverse possession to defeat earlier registered title.
Adverse possession — Registered Land Act s.134(1) — elements: factual possession and intention to possess — seasonal cultivation insufficient — failure to register adverse possession — variation of default judgment and rectification of land registry.
13 July 2023
Claim struck out for inordinate delay and abuse of process; defective sworn statement curable but did not avert strike-out.
Civil procedure — Want of prosecution — Strike out under Order 12 r56 — Court’s discretion and prejudice — Sworn statements: commissioning and service requirements (Order 18) — Abuse of process — Urgency in commercial matters.
13 July 2023
Whether a prosecution under the Corrupt Practices Act is ‘instituted’ on arrest/charging or only when the accused is called to answer the charge.
Criminal procedure – Corrupt Practices Act – requirement of DPP written consent to institute prosecutions – meaning of ‘instituted’ (arrest/charging/remand v. being called to answer/plead) – repeal of consent requirement and retrospectivity – General Interpretation Act s.14.
11 July 2023
Whether late service of a charge-sheet and pre-plea disclosure obligations justify adjournment and set timelines for evidence disclosure.
Criminal procedure — service of charge sheet; section 151(1) CP&EC — pre-plea disclosure of evidential material; fair trial and equality of arms; right to legal representation; adjournment and timelines.
3 July 2023
June 2023
Court varied ex parte injunction: no suppression found, serious issue to be tried on enforceability of teaming agreement; partial implementation permitted.
Interlocutory injunctions – ex parte disclosure – alleged suppression of material facts – enforceability of teaming agreements – adequacy of damages – variation of injunction to permit partial project implementation.
23 June 2023
Court varied ex parte injunction: allowed limited project start but restrained defendant from using $400,000 or implementing claimant’s component pending resolution.
Contract/NGO funding – Teaming Agreement and enforceability – interlocutory injunction – ex parte disclosure duties – adequacy of damages – balancing public interest in service delivery vs contractual rights.
23 June 2023
Unchallenged valuation awarded as market value; limited special damages proved but K10,000,000 general damages awarded for delay.
Land law – assessment of damages – unchallenged expert valuation adopted as market value – breach of contract damages – claimant must prove consequential loss; general damages awarded for delay/inconvenience – costs to claimant.
23 June 2023
22 June 2023
Where charged offences are not gazetted as exceptions, the High Court must try the accused by jury.
Criminal procedure – Trial by jury under s.294(1) Criminal Procedure and Evidence Code – Minister’s power under s.294(2) to Gazette exceptions – Criminal Procedure (Trials Without Jury) Order – offences not listed require jury trial.
22 June 2023
The applicant, a statutory public housing corporation, is protected by Order 34 Rule 4 from seizure and sale; enforcement suspended.
Civil procedure – suspension of execution – stay of enforcement; Public institution immunity – Order 34 Rule 4 – seizure and sale orders; Statutory corporations – government entity status and representation by Attorney General; Enforcement against public bodies – alternative procedures.
16 June 2023
Applicant with cannabis-triggered violent episodes granted bail subject to strict conditions and a mandatory mental-health treatment plan.
Bail — right to bail not absolute — interests of justice and Bail Guidelines — delay in prosecution and unlawful remand — substance-induced psychiatric risk — bail conditional on mental-health outpatient plan and strict security measures.
15 June 2023
An application to stay a statutory demand was dismissed as incompetent; a statutory demand is not an Order 28 enforcement order.
Civil procedure – Stay of execution – Suspension of enforcement of costs order – Statutory demand under Insolvency Act not an enforcement order under Order 28 – Competency of application – Registrar’s jurisdiction under Order 25 Rule 1 – Delegated decisions as High Court decisions – Res judicata – Inherent jurisdiction
13 June 2023
Whether a bank’s wrongful caution caused the claimant’s sale loss and whether the claimant must repay funds received without consideration.
Registered Land Act – cautions (ss.126–130) – wrongful lodgement of caution – unregistrable interest and requirement to have advanced money; Tort/Equity – damages for wrongful caution causing rescission of sale; Contract/Property – purchaser’s right to rescind upon discovering a caution; Restitution – action for money had and received; Defence of change of position; Burden and standard of proof (balance of probabilities).
13 June 2023
Wrongful caution on land led to claimant’s damages; bank recovers MK5.95 million received by claimant.
Registered Land Act – cautions (s.126–130) – wrongful lodgement of caution – unregistrable interest – requirement for bank to have advanced money on current account – remedies under s.130; Civil restitution – money had and received – receipt of bank funds without consideration entitling recovery; rescission of sale due to registered caution and consequential damages.
13 June 2023
Court dismissed challenge to anti-corruption investigation, finding allegations speculative and judicial review unjustified.
Administrative law – judicial review of investigative/prosecutorial actions; locus standi; prosecutorial discretion; ACB cooperation with foreign agencies (NCA); admissibility of allegedly illegally obtained evidence; limits of DPP/Attorney General supervision over ACB; arrest versus summons; availability of alternative remedies.
5 June 2023
Application for judicial review to quash ACB investigation and prosecution dismissed for lack of factual basis and alternative remedies.
Judicial review — prosecutorial and investigative decisions — locus standi — timeliness — cooperation with foreign agencies (NCA) — admissibility of illegally obtained evidence (discretionary) — scope of DPP/Attorney General supervision — arrest v summons — exceptional nature of quashing investigations.
5 June 2023
May 2023
Registrar may assess interest despite defendant's 'without prejudice' dollar-pegging claim; claimant awarded costs and assessment set down.
Civil procedure — Assessment of interest — Admissibility of 'without prejudice' communications — Registrar's jurisdiction under Order 25 Rule 1 to determine whether issue is contentious — Costs discretion under Order 31 Rule 3.
30 May 2023
Court consolidated two related suits over one loan offer, finding consolidation appropriate where borrower admitted default and issues are identical.
Commercial law – loan facilities contained in one offer – borrower default and lender's right to recall – injunctions as stopgap measures – consolidation of related proceedings to avoid abuse of process – sale of secured property and notice requirements – Loans Recovery Act applications where borrower admits default.
25 May 2023
Court refused to strike out claim for misnaming, ordered amendment of defendant's name and directed assessment of damages.
Civil procedure — Misnaming of party — Amendment of party name under Order 1 Rule 5 — Default judgment — Strike-out after judgment inappropriate; set-aside is proper remedy.
22 May 2023
19 May 2023
19 May 2023
16 May 2023
Employer breached statutory duty to guard dangerous machinery causing amputation; dismissal was unfair and claimant reinstated, damages to be assessed.
Occupational safety – Employer’s duty to fence or guard dangerous machinery – breach of s35 OSHWA establishing negligence; Contributory negligence – standard adapted to noisy, repetitive factory work – defence rejected; Causation – lack of guarding caused amputation; Employment law – burden on employer to prove redundancy under Employment Act s61 – dismissal unfair; Reporting obligations – failure to notify Director and Workers Compensation Trustee under OSHWA and Workers Compensation Act.
12 May 2023
Court entered judgment for the claimant on admitted loan liability and awarded costs; interest and costs to be assessed if not agreed.
Commercial law – loan default – admission of liability – judgment on liability despite disputed quantum – consent/agreed order inconsistent with court directions – assessment/taxation of interest and costs – enforcement of security/power of sale.
10 May 2023
Policy forcing Rastafarian children to cut dreadlocks for school admission violates rights to religion, education and equality.
Constitutional law – freedom of religion – manifestation by hair (dreadlocks) – right to education – equality and non‑discrimination – administrative law – policy (written or unwritten) amenable to review – Wednesbury irrationality and proportionality – reasonable accommodation – remedies: declarations, certiorari, mandamus, costs.
8 May 2023
Overtime claims require employee proof; unreasoned lump-sum awards for unfair dismissal must be set aside and reviewed.
Labour law — Unfair dismissal — Procedural fairness v substantive reason — Compensation assessment — Burden of proof for overtime on employee — Registrar/Assistant Registrar jurisdiction — Review under Rule 5A — Mitigation and contributory fault — Severance pay computation.
5 May 2023
Court held interdiction and prosecution null where suspension power rests with the President and Director enjoys statutory immunity absent alleged bad faith.
Administrative/constitutional law – judicial review of government action – permission to apply ex parte constitutes the review application; where no defence is filed claimant may seek scheduling conference or ask Court to end proceedings early – exception to mootness for decisions capable of repetition yet evading review – public officer immunity under Corrupt Practices Act (section 22) requires allegation/establishment of bad faith before proceedings – suspension/interdiction power of Director vested in President (section 6(3)).
5 May 2023
April 2023
Registrar found ambiguity in Order 13(6)(2) on restoring struck-out defences and referred the issue to the Judge.
Civil procedure – mediation – Order 13(6): striking out defence vs dismissal of claim; scope of restoration under Rule 6(2); Registrar’s powers under Order 25; referral to Judge for authoritative determination.
19 April 2023
Experienced employee’s failure to take available precautions defeated negligence and statutory duty claims against the employer.
Employer's duty of care; employee’s duty to take reasonable care; Occupational Safety, Health and Welfare Act (ss.13,18,58,65); contributory/sole negligence; res ipsa loquitur.
5 April 2023
An experienced worker’s failure to take available precautions defeated his claim of employer negligence and statutory breach.
Personal injury – employer’s duty under Occupational Safety, Health and Welfare Act – alleged breach of statutory duty – contributory negligence by experienced employee – causation and failure to prove employer negligence.
5 April 2023
March 2023
The claimant failed to prove serious long‑term injuries; court awarded MK900,000 for soft tissue injuries and MK750,000 costs.
Assessment of damages — Admissibility and weight of medical reports not prepared by the treating clinician — Quantum for soft tissue injuries — Requirement of credible evidence for claims of long‑term disability and loss of amenities — Costs on assessment.
31 March 2023
Default judgment set aside because a triable issue exists over premature commencement under Section 4; defendant ordered to file defence.
Civil procedure — Setting aside default judgment — Order 12 rule 21 CPR 2017; Statutory notice — Section 4 Civil Procedure (Suits by or against Government and Public Officers) Act — premature commencement; Riot Damages Act — discretionary ministerial power; Interests of justice; Triable issues.
31 March 2023
The applicants recovered damages only for false imprisonment; unpleaded and unproven heads were dismissed, award K1.5M each.
Constitutional/Delict — False imprisonment — Assessment of damages limited to pleaded relief — Evidential burden for special damages — Duration (20 hours) and circumstances relevant to quantum — Award K1,500,000 per claimant — Costs to be agreed or taxed.
28 March 2023
Magistrate must expressly assess and record that delay or expense would be unreasonable before refusing recall of witnesses under section 165.
Criminal procedure – section 165 CP&EC – recall of witnesses when trial continued by succeeding magistrate – qualified right to request recall – magistrate must expressly find that delay or expense would be unreasonable before refusing – failure to make required finding renders decision reviewable.
24 March 2023
Whether reliance on a Ministerial Budget Statement to calculate excise tax is lawfully reviewable and whether a Special Referee appeal was available.
Judicial review — Amenability where lawfulness/illegality alleged — Ministerial Budget Statement as basis for excise tax; legitimate expectation; alternative remedy — Special Referee jurisdiction under s121 Customs and Excise Act; interim injunction — adequacy of damages.
22 March 2023
Aggravating factors (premeditation, abuse of trust, pregnancy, HIV risk) outweighed mitigation; long concurrent custodial sentences imposed.
Criminal law — Sentencing for sexual offences — Defilement, rape and indecent practices — Abuse of trust, premeditation, victim pregnancy and miscarriage, HIV risk — First offender status and age not determinative — Concurrent long custodial sentences.
8 March 2023
Court imposed a lengthy custodial sentence for defilement, rape and indecent practices due to premeditation, abuse of trust and serious victim harm.
Criminal law — Sentencing — Defilement, rape and indecent practices in presence of a child — Aggravating factors: premeditation, abuse of trust, victim pregnancy and miscarriage, HIV‑positive assailant, sexual act in presence of a child — Upward sentencing trend for sexual offences — Custodial sentence imposed (concurrent terms).
8 March 2023
Court set aside a default judgment to determine contested estate issues on the merits; claimant ordered to pay costs.
Civil procedure – setting aside default judgment – service and content of summons (Order 5) – default judgment provisions (Order 12 r6 & r21) – reasonable cause and meritorious defence – discretion in interests of justice – deceased estates (Deceased Estate (Wills, Inheritance and Protection) Act ss.17,187).
6 March 2023
6 March 2023
February 2023
Continuation of an interim injunction pending judicial review of alleged unlawful and abusive tax enforcement by the revenue authority.
Judicial review — tax enforcement — interim injunction — serious question to be tried — adequacy of damages — balance of convenience — unclean hands — status quo ante.
21 February 2023
Magistrates’ courts lack inherent jurisdiction to stay and refer constitutional questions; bail refused for insufficient supporting information.
Bail — evidential burden on applicant; consideration of risk to witnesses post-investigation; seriousness of offence as factor in bail; magistrates' courts lack inherent jurisdiction to stay criminal proceedings or refer matters for constitutional certification; entrapment/agent provocateur claim was not a basis for referral in magistrates' court.
21 February 2023
Magistrate courts lack inherent jurisdiction to stay proceedings for constitutional certification; bail refusal upheld due to insufficient applicant evidence.
Criminal procedure – Bail – accused's evidential burden to raise facts for release; consideration of likelihood of witness interference and seriousness of offence – Magistrate courts' jurisdiction – lack of inherent jurisdiction to stay proceedings or refer matters for constitutional certification – Referral for certification – agent provocateur/entrapment allegation.
21 February 2023
Court awarded MK5,000,000 as total damages for loss of expectation of life and dependency, limited by the defendant's agreed cap.
Motor‑vehicle accident — assessment of damages — loss of expectation of life; loss of dependency — multiplier/multiplicand approach — conventional awards for expectation of life — default judgment and agreed cap on defendant’s liability (MK5,000,000.00).
20 February 2023
Permission to seek judicial review of ACB production notices dismissed for failing to disclose an arguable case; jurisdiction confirmed.
Financial Crimes Division jurisdiction; judicial review (permission stage); notices to produce under Corrupt Practices Act s.11(1)(c); specificity of investigative notices; suppression of material facts; investigatory delay and abuse of process; Wednesbury unreasonableness.
14 February 2023
A statutory Law Society may seek judicial review of public‑law decisions affecting the Anti‑Corruption Bureau; review is not barred by section 61 Courts Act.
Judicial review — jurisdiction to review magistrates' decisions — section 61 Courts Act distinction between suits and judicial review — locus standi of statutory Law Society to protect public interest — alternative remedies and exhaustion — interdiction as public law vs. private employment matter — ex parte stay applications and urgency.
8 February 2023
A guilty plea entered without confirming understanding and absence of an essential element invalidates the conviction.
Criminal procedure – Plea of guilty – Proviso to s251(2) CP&EC requires court to ascertain accused’s understanding and unqualified admission; Elements of offence – lack of licence or permit is essential for possession of charcoal under s68(3)(a) Forestry Act; Conviction cannot stand where facts do not prove essential element; Retrial discretionary – declined where accused detained lengthy and material evidence may be lost.
6 February 2023
Claimant failed to exhaust the statutory appeal under section 121 and missed the three-month filing deadline, so judicial review was dismissed.
Administrative law — Judicial review barred where alternative remedy available under s121 Customs and Excise Act; Special Referee’s jurisdiction covers disputes as to amount of duty (including formula issues) — Requirement to exhaust statutory appeal — Time limit for judicial review (3 months) — Post-decision discussions do not extend limitation period.
6 February 2023
Stay of execution denied where applicant failed to prove respondent’s impecuniosity and appeal prospects were not decisive.
Civil procedure – Stay of execution pending appeal – Discretionary relief – Prospects of success on appeal not decisive – Applicant must prove respondent’s impecuniosity – Balance of injustice test.
1 February 2023
Court refused to hear bail application and directed counsel to file it before the judge presiding over the advanced-stage trial.
Criminal procedure — Bail pending trial — Court declined to entertain bail application because substantive trial at advanced stage before judge seized of matter — Application to be filed with trial judge for proper case management.
1 February 2023
January 2023
Failure to afford a proper hearing rendered the recruit’s dismissal unfair; compensation awarded instead of reinstatement.
Employment law — Unfair dismissal — Procedurally fair administrative action — Right to be heard (audi alteram partem) — Sham disciplinary hearing — Remedy: compensation where reinstatement impracticable.
24 January 2023