High Court of Malawi Civil Division - 1993

54 judgments
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Results. 54 judgments found.

54 judgments
December 1993
Failure to give statutory notice of dishonour under s48 bars summary judgment on a dishonoured cheque.
  • Bills of Exchange Act s48 — notice of dishonour — effect of non‑compliance (drawer discharged); Summary judgment — appropriateness where statutory notice not given; Cheque-as-cash principle distinguished where notice absent.
31 December 1993
A pleading will not be struck out for imprecision if, read as a whole, it discloses a reasonable cause of action.
  • Civil procedure — strike‑out of pleadings — Order 18 r.19 — reasonable cause of action — evidence inadmissible on strike‑out — pleadings must be read as a whole — imprecision not fatal — right to amend — rent/mesne profits arising from holding over.
30 December 1993
Representative action disallowed where employees have separate contracts; aggregating small claims in High Court is not per se abuse.
  • Representative actions — employment law — separate severally-entered contracts — no common interest; Abuse of process — aggregation of small claims in High Court not per se abuse; High Court original jurisdiction; amendment and joinder.
30 December 1993
Court approved defendant's compromise, ordering K7,200 paid and distributed to the widow, mother and minor children.
  • Civil procedure — Minor settlements — Order 80, rules 10 and 11 — Court approval required to protect persons under disability — Assessment of benefit to minors — Quantum based on minimum wage and multiplier — Distribution of settlement funds.
29 December 1993
Plaintiff awarded K3,000 for pain and suffering from non-permanent soft-tissue injuries; no loss of earnings awarded.
  • Personal injury — Soft-tissue injuries, cuts and bruises — No permanent incapacity — Non-pecuniary (general) damages for pain and suffering — No loss of earnings or amenities — Quantum K3,000 — Costs on subordinate court scale.
21 December 1993
Injured labourer awarded K8,000 for pain and K3,000 for loss of earning capacity due to substantial risk to future employability.
  • Personal injury — damages for pain and suffering and loss of amenities — award for amputation and ongoing disability; Damages — loss of earning capacity where plaintiff remains employed — test of substantial (not speculative) risk of diminished employability; Quantification of global award using current earnings and expected working life.
21 December 1993
Assessment of loss of dependency using multiplier/multiplicand method; no reduction for remarriage absent evidence.
  • Damages—loss of dependency; multiplier and multiplicand method; discounting of future annuities; assessment in absence of defendants; remarriage prospect not proved.
10 December 1993
Non‑compliance with Order 13 r.8 and Order 47 r.1(3) prevents an automatic stay of execution absent extension or compliance.
  • Civil procedure — Stay of execution — Order 13 r.8 — Requirement to issue summons within 14 days — Affidavit and full and frank disclosure required by Order 47 r.1(3) — Section 15 Sheriff Act — Extension of time and "unless" order.
10 December 1993
Mandatory interlocutory injunction granted to recover company car from former employee due to risk of irreparable loss.
  • Property/owners’ rights — possession by former employee — fringe benefit — mandatory interlocutory injunction — irreparable harm and balance of convenience — vehicle recovery (registration GH 335 F3).
1 December 1993
November 1993
Plaintiff entitled to recover substitute hire charges as consequential loss despite third‑party arrangements or hirer’s licensing defects.
  • Negligence — consequential loss — recovery of substitute vehicle hire charges; evidential sufficiency of hire arrangements; third‑party payments and reimbursements — gratuitous payments not deductible; enforceable third‑party obligations recoverable.
29 November 1993
Summary judgment on dishonoured cheques dismissed because notice of dishonour was not pleaded; defendant granted unconditional leave to defend.
  • Bills of Exchange — dishonour — notice of dishonour required to establish cause of action; Order 14 summary judgment — affidavit must verify claim and address existence of defence; defective statement of claim precludes summary judgment; unconditional leave to defend.
19 November 1993
Default judgment set aside where defendant disclosed triable issues despite irregularity and procedural lapses.
  • Civil procedure — setting aside default judgment — irregular/premature entry of judgment — Order 13 r 9 — affidavit of merits/triable issues — defendant need not always explain default — discretion exercised despite procedural lapses.
17 November 1993
Whether a defendant’s prima facie triable defence justifies setting aside a regular default judgment.
  • Civil procedure — setting aside default judgment — service by post (Order 3 r.2) — notice of intention to defend — statement of claim not required for liquidated claim — triable issues/defence (rejection of goods, mitigation/resale) — discretion to allow defence.
15 November 1993
Default judgment awarding unpaid allowance, conversion and defamation damages totalling K2,800 to the plaintiff.
  • Employment law — unpaid professional allowance; Conversion of goods (break-in and removal) vs trespass — cannot double recover; Defamation — damage to credit and reputation; Default judgment and assessment of damages.
13 November 1993
Registrar validly granted an ex parte conditional stay of execution under Order 47(1) despite an existing instalment order.
  • Civil procedure — Stay of execution — Order 47 r.1 — Registrar's jurisdiction to grant ex parte stays and impose conditions — Payment by instalments — Distinction from section 11(c)(x) applications.
12 November 1993
Summary judgment refused where defence amounted to confession and avoidance, not a clear admission of liability.
  • Civil procedure — Summary judgment under Order 27 r.3 — Admissions in defence — Requirement of plain and unambiguous admission — Confession and avoidance — Pleadings to be read as a whole.
11 November 1993
Summary judgment on dishonoured cheques dismissed for failure to plead notice of dishonour as required by the Bills of Exchange Act.
  • Civil procedure — Summary judgment (Order 14) — Bills of exchange/cheques — Requirement to plead notice of dishonour under s.48 of the Bills of Exchange Act — Failure to plead notice means no cause of action; summary judgment dismissed.
2 November 1993
A direct claim against an insurer fails where the policy and statute exclude employee injuries arising in the course of employment; action dismissed as abuse of process.
  • Road Traffic Act s65A(1) — direct action against insurer; policy exclusions and s62A — employee injuries arising in course of employment excluded from cover; Order 80 r11 — court approval of settlements for persons under disability (not for disapproval); abuse of process — striking out proceedings.
2 November 1993
October 1993
Plaintiff awarded damages for severe workplace injuries: substantial compensation for pain, loss of amenities and reduced earnings; special damages denied.
  • Personal injury — assessment of damages — general damages for pain and suffering and loss of amenities — calculation of loss of earnings using multiplier/multiplicand and working life to 55 — award of unpleaded past/future earnings loss — unproved special damages dismissed.
29 October 1993
Summary possession under Order 113 inappropriate where factual disputes or estate interests require a trial.
  • Possession proceedings — Order 113 originating summons — dispute of fact on occupation/licence of predecessor in title — potential proprietary interest via deceased owner's estate — summary procedure inappropriate — convert to writ under Order 28 r 8.
27 October 1993
Whether the defendant's affidavit disclosed factual grounds for a defence sufficient to set aside a default judgment.
  • Civil procedure — setting aside default judgment — affidavit of merit required — allegations must raise facts from which a defence or triable issue can be inferred; Appropriation/approbation — application for instalments does not necessarily constitute approbation; Defence of payment — must be supported by evidence in affidavit; Court may allow supplementary affidavit where initial affidavit is deficient.
25 October 1993
Whether a passenger may sue an insurer directly under s65A when the policy excludes passenger liability.
  • Road Traffic Act s65A — direct action against insurer; privity of contract; policy exclusions for passengers; statutory requirements (s61) for cover.
19 October 1993
Stay of execution refused because respondent’s assets meant a successful appeal would not be nugatory.
  • Civil procedure — Stay of execution pending appeal — Whether appeal will be nugatory — Court’s discretion to protect successful litigant’s entitlement — Payment into court as protective condition.
14 October 1993
Court awarded K13,780 for loss of dependency under s.7, allocated among the widow, five children and a sister-in-law.
  • Wrongful death — Loss of dependency under s.7 Statute Law (Miscellaneous Provisions) Act — Quantum based on deceased’s net salary and agreed dependency fraction — Default judgment enforcement — Distribution of award among widow and dependents.
6 October 1993
September 1993
Non-compliance with prescribed originating summons form and service requirements warrants dismissal; plaintiff may refile correctly.
  • Civil procedure — Originating summons — Non-compliance with Orders 7 and 28 — Prescribed form and acknowledgement of service required — Court will not restore defective pleadings — Dismissal with costs; liberty to refile.
24 September 1993
August 1993
Court refused to discharge interlocutory injunction where defendant had notice but no inter partes hearing and irreparable harm risk existed.
  • Interlocutory injunction — ex parte v inter partes — notice and absence of hearing — discharge of injunction under Order 29/1/17 RSC — preservation of status quo — irreparable harm — disputes of fact not resolvable on affidavits.
27 August 1993
Enforcement adjourned; sale of debtor’s house refused pending taxation of plaintiff’s bill of costs and resolution of set‑off.
  • Civil procedure — execution and stay — payment by instalments — set‑off where opposing party has un‑taxed bill of costs — taxation of costs before enforcement — sale of debtor’s property — fairness in interim enforcement orders.
26 August 1993
A non‑defendant firm lacked locus standi to set aside a default judgment against a limited company; proper remedy was notice of claim or intervention.
  • Civil procedure — Default judgment — Locus standi of third parties to apply to set aside — Order 13 Rule 9 — Inherent jurisdiction to prevent substantial injustice — Wrongful seizure of third‑party goods; notice of claim and intervention remedies.
24 August 1993
Interim injunction granted where employee's licence to occupy employer-provided house ended on resignation and damages inadequate.
  • Interim injunctions — American Cyanamid principles — licence to occupy employer-provided housing — termination of licence on resignation — balance of convenience — Registered Land Act inapplicability.
6 August 1993
July 1993
Court granted a stay to enforce an arbitration clause; time limits can be extended under the Arbitration Act.
  • Arbitration clause — stay of proceedings — arbitral award as condition precedent — correspondence construed as settlement attempts not refusal to appoint arbitrator — court’s power to extend arbitration time under s.14(2) Arbitration Act — readiness to arbitrate justifies stay.
29 July 1993
Employer liable for inadequate machine guarding; plaintiff partly negligent; damages reduced by 25%.
  • Employer's duty of care — machinery guarding — inadequate guard leaving gap between chain and conveyor — contributory negligence by employee — apportionment of liability — damages for amputation.
16 July 1993
June 1993
Lessor lawfully repossessed a leased vehicle; applicant’s post‑seizure duplicate documents constituted fraud, so injunction dismissed.
  • Property law — lease‑hire — lessor’s proprietary interest and endorsement on registration book; Repossession — lawful seizure by agent on lessor’s instruction; Fraud on the court — post‑seizure duplicate registration and false documents; Interim injunction — discharge where relief procured by fraud.
18 June 1993
May 1993
The applicant awarded substantial damages for serious, permanent injuries caused by the respondent's negligent driving.
  • Motor-vehicle negligence — Assessment of damages — Personal injuries — Serious and permanent injury — Closed head injury and open fracture with deformity — Application of restitutio in integrum and reliance on comparable awards — Default defendants absent at quantum assessment.
31 May 1993
Failure to obtain required ministerial consent rendered the local authority’s contract illegal, barring the contractor’s recovery.
  • Public law / procurement — Local Government (Urban Areas) Act — statutory tender requirements — ministerial consent for accepting non‑lowest tender — failure to obtain consent renders award and contract illegal and void ab initio — innocent contractor cannot recover under illegal contract.
27 May 1993
A nationally broadcast false allegation that the plaintiff stole money was defamatory per se; K300,000 awarded; exemplary damages considered.
  • Defamation — slander actionable per se — nationwide broadcast — aggravating factors (plaintiff’s high reputation, extent of publication, political motive, lack of apology) — exemplary damages — Rookes v. Barnard considered but Malawian courts retain broader discretion — compensatory award K300,000
26 May 1993
Court awarded compensatory and, where justified, exemplary damages for prolonged false imprisonment and destruction of property by public officers.
  • Civil liability — False imprisonment and trespass to land and goods; exemplary (punitive) damages versus aggravated (compensatory) damages; assessment of quantum; misconduct by public officers; deterrence and punishment.
19 May 1993
Arbitrary police arrest and detention without lawful cause attract discretionary general and exemplary damages.
  • False imprisonment — assessment of damages — discretionary nature of awards for loss of liberty and injury to feelings — exemplary damages against public officers for arbitrary arrest and delay in release after court order.
19 May 1993
Interlocutory injunction discharged where equity showed respondent might be unjustly enriched and substantive issues were for trial.
  • Interim injunctions — vacation/discharge — equitable principles — bills of exchange — remittance and exchange control — alleged fraud and unjust enrichment — interlocutory discretion.
19 May 1993
Summary judgment refused where authenticity of minutes, authorization of directors’ remuneration and tax-evasion allegations raised triable issues.
  • Civil procedure — Summary judgment (Order 14 r.3(1)) — Genuine triable issues of fact — Authenticity of minutes — Directors’ remuneration and authorization — Alleged tax-avoidance entries — Counterclaim treated as defence — Discovery and trial directions.
18 May 1993
April 1993
Application to set aside interlocutory default judgment granted due to unfairness from procedural irregularity and waiver by the respondent.
  • Civil procedure — setting aside interlocutory default judgment — extension of time for challenge to ex parte orders — change of legal representation — waiver of irregularity — requirement to show meritorious defence.
29 April 1993
Section 65A permits a claimant to sue an insurer directly without first proving the insured's liability.
  • Road Traffic Act s65A — statutory right of third party to sue insurer directly — interpretation of "any person having a claim" — distinction from UK Third Parties (Rights against Insurers) Act 1930 — non-joinder not fatal; pleadings must disclose cause of action.
27 April 1993
Summary judgment for most of claim; defendant may contest a disputed invoice only if that sum is paid into court.
  • Civil procedure — Order 14 summary judgment — defendant may raise bona fide defences despite offering to pay by instalments or issuing post‑dated cheques; quotation error and alleged poor workmanship can constitute triable issues; conditional leave to defend subject to payment into court.
13 April 1993
Administrators must account and distribute the intestate estate; pension death benefits to nominated beneficiaries are excluded and prior disbursements are offsets.
  • Succession and intestate distribution — administrators' duty to account — pension death benefits nominated to beneficiaries — characterization of death benefits as not part of estate — fair distribution under Wills and Inheritance Act — advances treated as offsets against shares.
8 April 1993
Default judgment set aside due to excessive endorsed costs and unliquidated tortious claim; defendant to serve defence within fourteen days.
  • Civil procedure — Default judgment — Notice of intention to defend — duty to lodge notice with court; process‑server employed by plaintiff insufficient; irregularity where endorsed costs exceed statutory fourteen‑day costs; tortious claim for inducing breach yields unliquidated damages and cannot support final default judgment; setting aside default judgment where real disputes and accounting enquiries exist.
6 April 1993
Whether an insurer can be struck off where passenger cover is non‑compulsory turns on the actual policy terms, not section 62 alone.
  • Road Traffic Act — section 62/62A — compulsory third‑party insurance excludes passenger cover for vehicles not habitually carrying passengers for hire or reward; scope of insurer liability depends on policy terms; strike‑out inappropriate where policy not produced; contributions by passengers do not alone establish hire or reward.
5 April 1993
March 1993
A Registrar has no jurisdiction to decide a statutory High Court-to-subordinate-court transfer; the matter must go to a Judge.
  • Courts Act — Registrar’s jurisdiction — Transfer of proceedings to subordinate courts — Application under statute — Order 107 (UK practice) not applicable without enabling Malawi legislation — Section 29 and High Court practice — summons remitted to Judge.
24 March 1993
Defendant negligent in turning across plaintiffs’ lane; contributory negligence not available when unpleaded; employer-paid non‑contributory medical costs not recoverable.
  • Road traffic — negligence — duty to keep proper lookout before turning — right of way of following motorists — contributory negligence must be pleaded — non-recoverability of employer-paid non‑contributory medical expenses as special damages.
19 March 1993
A bank may set off depositor funds where the depositor gave a written guarantee for a third party's debt.
  • Banking law — payment to third party — funds deposited for remittance; Guarantee/suretyship — collateral contract in writing — Statute of Frauds; Right of set‑off — bank’s entitlement to apply deposited funds against guaranteed debt.
5 March 1993
Occupant in possession may sue in trespass; default motion under Order 19 r7(9) grants injunction and nominal damages.
  • Property law — Trespass — Possession and right to sue — Occupant under licence may sue in trespass; Civil procedure — Default judgment under Order 19 r7(9) — Injunction; Damages — Nominal damages for trespass absent actual loss.
5 March 1993
February 1993
Police unlawfully cancelled a lawful political rally permission, breaching equal-treatment regulations and freedom of association.
  • Public law — administrative action — cancellation of permission for political rally — Regulation 34 (Referendum Regulations) — equal treatment of special interest groups — freedom of political association — declaratory relief under Order 15.
23 February 1993