High Court of Malawi

4,012 judgments

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4,012 judgments
Citation
Judgment date
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
May 2022
Claimant cyclist proved on balance of probabilities that defendant negligently struck him; judgment and costs awarded.
Motor vehicle negligence – duty to keep proper lookout and drive at a speed to stop within visible distance – failure to stop after collision – credibility findings and balance of probabilities – assessment of damages.
31 May 2022
Whether cancellation of an industrial rebate without a hearing breached the claimant’s constitutional right to fair administrative action.
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31 May 2022
A magistrate may try a theft charge and decide ancillary land-ownership issues necessary to resolve the criminal matter.
Criminal law – Jurisdiction of magistrate in theft prosecutions – Ancillary civil issues (land ownership) – Magistrates may resolve ownership questions necessary to determine criminal liability even if value exceeds civil jurisdiction.
30 May 2022
Whether ACB may cooperate directly with foreign agencies under MACMA and whether hospital handcuffing violated constitutional rights
Arrest law – hospital arrests and use of restraints; Constitutional rights – inhuman/degrading treatment (handcuffing); Mutual Assistance in Criminal Matters Act s5(1) – ACB may cooperate with foreign enforcement agencies without prior AG sanction; Admissibility of illegally obtained evidence – discretionary rule in Malawi; Corrupt Practices Act s42 – DPP consent not required prior to arrest/remand (time‑limited).
30 May 2022
An aggrieved party to proceedings cannot use Order 23 r.8 (CPR) to attack a consent order; appeal or a specific action is the proper remedy.
Civil procedure — Consent order — Variation or setting aside — Order 23 r.8 CPR applies to non‑parties directly affected, not to persons who are parties; remedy for a party aggrieved by a consent order is appeal or a specific action to set it aside — Application to strike terms of consent order dismissed as misconceived.
30 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