High Court of Malawi

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4,012 judgments
Citation
Judgment date
March 2022
High Court reviews magistrate's interlocutory refusal, orders PSU report released and investigators compelled to testify for fair trial.
Criminal procedure — High Court review of subordinate court interlocutory orders; fair trial rights and disclosure under Section 42(2)(f) of the Constitution; relevance and compellability of Professional Standards Unit investigators; Sections 25–26 Courts Act and Sections 195, 201, 360, 362 CP&EC.
8 March 2022
On appeal, a seven-year custodial sentence for acts intended to cause grievous harm was held not manifestly excessive and was confirmed.
Criminal law — sentencing for acts intended to cause grievous harm (s235 Penal Code) — appellate review of sentence — manifest excess or error in principle required to interfere; observation of injuries in court (s260); intoxication and premeditation issues; mitigating factors considered.
8 March 2022
Appellate court confirmed seven-year custodial sentence for acts intended to cause grievous harm, finding it not manifestly excessive.
Criminal law – Sentencing – Acts intended to cause grievous harm (s235 Penal Code) – Appellate review of sentence – manifestly excessive/wrong in principle – consideration of mitigating factors (first offender, guilty plea, youth) – alleged intoxication – evaluation of visible injuries without medical report.
8 March 2022
Court summarily dismissed application to transfer an appeal to the Principal Registry, directing re-filing at Lilongwe and payment of fees.
Criminal procedure — Forum for appeals — Administrative practice requiring Dedza matters to be remitted to High Court Lilongwe District Registry; Motion to change registry lacking legal authority; Irrelevance of relatives’ presence; Section 351 CP & EC and High Court’s appellate handling powers.
7 March 2022
Court granted bail pending trial for accused murder suspects, applying Bail Guidelines and imposing conditions.
Bail pending trial — murder charge — Bail Guidelines Act factors (evasion, witness interference, danger, public order) — court's duty to weigh accused’s personal circumstances — conditions of bail — direction to expedite committal and disclosure.
4 March 2022
Applicant on prolonged remand granted bail where prosecution did not oppose and trial was not imminent.
Bail — Right to bail under Constitution s.42(2)(e) — Bail Guidelines Act 2000 factors — Interests of justice — Prolonged remand — Burden on prosecution to justify detention.
4 March 2022
Prolonged pre-trial detention without imminent trial justified grant of bail after balancing accused’s circumstances against interests of justice.
Criminal procedure – Bail pending trial – Interests of justice under s.42(2)(e) Constitution – Bail Guidelines Act 2000 factors (flight risk, witness interference, danger to community, public order) – Prolonged pre-trial detention – Duty of State to demonstrate why bail should be refused – Court’s independent balancing duty.
4 March 2022
Applicant on murder charge granted conditional bail pending trial; court weighed Bail Guidelines and ordered expedited steps.
Bail pending trial; Bail Guidelines Act — criteria (flight risk, witness interference, danger to community, public order); Section 9 — weighing accused’s personal interests against interests of justice; conditional bail and direction to expedite trial.
4 March 2022
Magistrates' courts lack jurisdiction to hear workplace injury claims commenced under the Workers’ Compensation Act.
Jurisdiction — statutory nature of jurisdiction; Workers’ Compensation Act — limited conferment of jurisdiction to Chief Resident Magistrate (appeals and enforcement); subordinate courts lack jurisdiction to hear claims commenced under the Act; section 63 — preservation of civil suits in respect of negligence subject to set-off provisos; amendment cannot cure absence of jurisdiction.
4 March 2022
Claim dismissed for failure to prove the bottle's origin, causation, and actionable nervous shock.
Product liability – manufacturer’s duty of care; proof of origin and causation; res ipsa loquitur inapplicable where product was not under sole control; requirement of medical and scientific evidence to establish nervous shock and nexus to contaminants.
2 March 2022
Claimant failed to substantiate claim by sworn evidence; summary judgment declined and matter referred to mediation.
Civil procedure — Summary judgment — Order 12 rules 23–26 — Claimant must substantiate plea by sworn statement; pleadings alone insufficient — Deficient defence should be challenged by strike-out, not summary judgment — Guidance from Easyair (EWHC).
1 March 2022
February 2022
The claimant succeeded in libel where false, malicious imputations defeated fair-comment and privilege defences; apologies and damages ordered.
Defamation (libel) – public interest reporting – fair comment and qualified privilege – malice defeats privilege – justification (truth) and burden of proof – remedies: apology, damages, costs.
28 February 2022
Rehearing allowed limited to cross‑examination where defaulting defendant showed promptness, good reason, and reasonable prospects.
Civil procedure – rehearing of judgment entered in absence – Order 16 r 7 – promptness, good reason (law‑firm software failure), reasonable prospects – sealing and citation defects not fatal.
25 February 2022
A bare/general denial contrary to CPR Order 7 warrants striking out the defence and judgment for the claimant.
Civil Procedure Rules 2017 — Order 7 Rules 6 & 7 — pleading requirements; general/bare denial; strike out of defence; holding defences; amendment of statement of case; interlocutory procedure; duty to exhibit amended pleadings and file skeleton arguments.
24 February 2022
Sworn statements containing legal argument and opinion may be expunged; expert evidence requires prior court permission.
Civil procedure — Admissibility of affidavits — Order 18 r6: affidavits must contain facts deponable from personal knowledge, not legal argument or opinion — Expert evidence — Order 17 r19: court permission required to call expert evidence; must identify issue requiring expert — Points of law — Order 16 r6(2): where facts agreed, court may decide questions of law — Striking defective affidavits; nullity where admissible and inadmissible material interwoven.
18 February 2022
An order that terminates prosecution and sets accused at liberty constitutes a final, appealable order under section 346.
Criminal procedure – Appealability of subordinate court rulings – Meaning of "order" in s.346 – Distinction between interlocutory and final orders – Stay/entrapment orders and release of accused as final and appealable – High Court review jurisdiction in criminal matters.
17 February 2022
Assessment awarded K6,313,282.84 for fire losses; negligence is not a separate head of damage; police inventory and quotations accepted.
Civil damages — assessment after default judgment — admissibility of police report and market quotations for special damages — negligence not a distinct head of damage — restitutionary approach with uplift for delay.
16 February 2022
Application to amend notice of appeal and stay enforcement is premature until the appeal record is settled; interim non-enforcement ordered.
Civil procedure – Appeals – Entry of appeal; Order 111 rules 10, 11 and 19 – Record of appeal must be settled and filed before Supreme Court is seized – Applications to amend notice of appeal or stay enforcement premature until appeal entered – Interim restraint on enforcement pending record settlement – Costs each party to bear.
15 February 2022
Administrator General appointed; Letters of Administration revoked; audit and restitution ordered after veil lifted and fraudulent asset disposals found.
Probate and intestacy – scope of estate – distinguishing personal assets from company assets – lifting corporate veil where company used to defeat inheritance rights – revocation of Letters of Administration obtained by material misrepresentation – appointment of Administrator General – audit and restitution orders – protection of minor dependants.
15 February 2022
Claimant proved a likely forged transfer to a subsequently-created trust; court ordered rectification restoring original joint ownership.
Registered Land Act – registration vests leasehold title; transfer by instrument — requirement of prescribed form and witnessing; alleged forgery of transfer — proof on balance of probabilities; transfer to trust created after transfer — invalid; rectification of register for fraudulently obtained registration.
14 February 2022
Landlord's failure to remove prior occupiers constituted breach; frustration, insurance and arbitration defenses rejected.
Contract law — valid written contracts for traffic management — landlord's duty to provide access and remove prior occupiers — frustration by third party; foreseeability and prior knowledge — insurance clause and arbitration clause do not absolve landlord from liability for fundamental breach — damages for loss of contract performance.
10 February 2022
A prior summary judgment on liability does not automatically bind new claimants; each must litigate negligence on the merits.
Civil procedure – summary judgment – res judicata – effect of prior judgment on separate claimants – consent order as compromise on damages – negligence claims from quarry blasting.
10 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.
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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