High Court of Malawi Civil Division - 2018

45 judgments

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45 judgments
Citation
Judgment date
November 2018
Registrar lacked jurisdiction to set aside or stay a final appellate order; fraud or incapacity challenges require appeal or fresh action.
Civil procedure – Registrar's jurisdiction under Order 25 CPR – expressio unius – challenge to final judgment obtained by fraud: remedy by appeal or fresh action – incapacity defence raised post-final judgment – assessment of damages directed by appellate court.
29 November 2018
High Court dismisses appeal, holding severance and pension payments were properly dealt with and factual findings are final.
Labour law – retrenchment – severance pay – appealability of factual findings from Industrial Relations Court under s.65 – pension/provident fund payments – discovery/refusal – fishing expedition.
2 November 2018
September 2018
Claimant awarded replacement cost and K9,000,000 for loss of business after vehicle burned in police custody.
Police seizure and custody of vehicle — vehicle destroyed while in custody — damages: replacement cost awarded where irreparable; loss of use/profit recoverable for profit-earning chattel where proved — award of K5,000,000 replacement and K9,000,000 loss of business.
19 September 2018
June 2018
Whether the respondent unlawfully reallocated leased land without hearing or complying with constitutional expropriation procedures.
Judicial review — public authority as proper respondent — natural justice — right to be heard — land reallocation and expropriation — compliance with section 44(3) Constitution — right to property (section 28) — Wednesbury unreasonableness.
28 June 2018
The Regional Commissioner unlawfully reallocated leased land without affording the applicant a hearing or complying with section 44(3) of the Constitution.
Administrative law – Judicial review – Natural justice – Right to be heard – Reallocation/re‑entry onto leased land – Expropriation under section 44(3) of the Constitution – Procedural fairness and Wednesbury unreasonableness – Proper respondent in judicial review of public authority action.
28 June 2018
Whether mandatory s91 publication authorises seizure and sale for unpaid rates and precludes instalment relief absent ordinary debt proceedings.
Local Government Act s91 – seizure and sale for unpaid rates – mandatory Gazette and newspaper publication; Rates attach to property; s78 – payment pending objection; s91(7) – distinctness from ordinary debt recovery; instalment relief not available in s91 proceedings.
11 June 2018
May 2018
Court awarded K4,701,536 for wrongful death: expectation of life and dependency; special damages dismissed for lack of proof.
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16 May 2018
April 2018
Assessment of quantum in personal injury: awarded damages for pain, amenities, disfigurement and nominal lost earnings.
Personal injury – assessment of quantum – general damages for pain and suffering, loss of amenities, disfigurement and loss of earning capacity – use of comparable awards – nominal award where no evidence of earnings – 5% allowance for currency depreciation.
30 April 2018
Assessment of unfair dismissal award: calculation of compensation, severance and compound interest under the Employment Act.
Employment law – unfair dismissal – remedy under s.63(4) – assessment of compensation; Severance pay – First Schedule calculation; Compound interest on severance (commercial lending rate) – limitation on awarding new relief at assessment; Costs refused.
27 April 2018
Alleged misleading by counsel does not constitute good cause for a stay of execution; stay is discretionary.
Civil procedure — Stay of execution — Discretionary relief — Applicant must show good cause — Misleading by counsel insufficient — Remedies include suit against counsel or appeal — Order 47 Rule 1 RSC.
24 April 2018
An insurer's consent order and payment do not automatically justify summary judgment against the insured.
Summary judgment; consent order; insurer settlement; insured not party; Road Traffic Act s148; unliquidated damages; triable issues on negligence and apportionment; leave to defend.
23 April 2018
The applicants' interlocutory injunction in a WhatsApp defamation claim was continued pending trial; damages deemed potentially inadequate.
Defamation — publications on social media (WhatsApp) — interlocutory injunction — triable issue — adequacy of damages for reputation harm — requirement for full and frank disclosure — balance of convenience.
19 April 2018
After failed mediation, the court referred the dispute to trial to decide whether the second defendant was properly installed as village headman.
Civil procedure — Mediation — Failure to reach settlement — Referral to trial under Order 13 Rule 9(2) — Determination of proper installation of village headman.
10 April 2018
After mediation failed, the court referred the land entitlement dispute to trial and ordered transfer to the Magistrate’s Court.
Civil procedure – mediation failure – referral to trial under Order 13 rule 9(2) – land dispute – transfer from High Court to Magistrate’s Court for hearing.
10 April 2018
After failed mediation, court referred the claimants' land entitlement dispute to trial and transferred it to the Magistrate's Court.
Land dispute – entitlement to land – mediation failure – referral to trial – transfer to Magistrate’s Court – Order 13 Rule 9(2) High Court (Civil Procedure) Rules.
10 April 2018
Appeal dismissed because the appellant failed to comply with Order 33, rendering the appeal not ready for hearing.
Civil procedure – appeal readiness – compliance with Order 33 of the Subordinate Court Rules – procedural dismissal for non‑compliance.
9 April 2018
An appeal was dismissed because the appellant failed to comply with Order 33, rendering the matter not ready for hearing.
Civil procedure – Appeal – Procedural compliance – Failure to comply with Order 33 of the Subordinate Court Rules – Appeal not ready for hearing – Dismissal for non-compliance.
9 April 2018
Appeal hearing dismissed for failure to comply with Order 33 of the Subordinate Court Rules.
Civil procedure — Appeal — Readiness for hearing — Non‑compliance with Subordinate Court Rules (Order 33) — Dismissal of hearing.
9 April 2018
Summary judgment refused where defendant raised genuine factual disputes about contractual variation and estoppel requiring trial.
Civil procedure – summary judgment (Order 14) – genuine triable issues – contract variation through agent – acceptance of late payments – estoppel – whether time was of the essence.
3 April 2018
Interim injunction refused where damages were adequate and the applicant suppressed a material fact (trustee status).
Interim injunctions – adequacy of damages as alternative remedy – injunction refused where damages adequate; Duty of full disclosure – suppression of material facts vitiates interlocutory application; Internal association law – disciplinary powers and eligibility for office under constitution; Natural justice – right to be heard in disciplinary processes.
3 April 2018
March 2018
Failure to publish Council appointments in the Gazette rendered the Council unconstituted and its disaccreditation decision void if made while accreditation subsisted.
Administrative law — Judicial review — Grounds: illegality, irrationality, procedural impropriety — Statutory interpretation of "academic cycle" — Accreditation law — Mandatory gazetting of public body appointments; failure renders acts void.
27 March 2018
The applicant failed to show a triable issue of land ownership; interlocutory injunction dismissed.
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21 March 2018
The applicant failed to prove continued possession of customary land; claim dismissed; respondents ordered to provide a token of appreciation; costs borne individually.
Customary land – possession and control – burden on balance of probabilities; church property as collective; failure to prove continued possession; claim dismissed; token of appreciation ordered; parties to bear own costs.
20 March 2018
Personal injury claim dismissed as statute‑barred where the writ was filed after the three‑year limitation and plaintiff did not attend hearing.
Limitation Act – personal injury – three-year limitation for actions for damages for negligence – "brought"/filed within statutory period; Civil procedure – Order 14A point of law determination; Order 32 r.5 – hearing in absence where party duly served; statute-barred claim – dismissal with costs.
16 March 2018
Action struck out as abusive and premature for duplicating a pending appeal and for failing to exhaust internal party remedies.
Party constitution — internal dispute resolution (Article 56) — exhaustion of internal remedies — abuse of court process — duplicative litigation and risk of conflicting judgments — striking out proceedings.
6 March 2018
2 March 2018
Plaintiff failed to prove occupier or agency status or negligence; claim dismissed and costs awarded to defendants.
Occupiers' liability — proof of occupier status; Agency — requirement of evidence to prove agency/consent; Negligence — duty, breach and causation on balance of probabilities; Evidentiary inconsistencies and trespasser status affect liability.
2 March 2018
Taxation of costs held premature because matter was not concluded; taxation deferred until final determination.
Civil procedure – Taxation of costs – Order 62 r.8(1) – Costs not taxable until conclusion of matter unless court expressly orders earlier taxation – "to be taxed or agreed" does not equate to "taxation forthwith" – premature taxation dismissed.
1 March 2018
1 March 2018
February 2018
Registrar has no authority to grant summary judgment; defective sworn statement cannot be used without court leave.
Civil procedure — Summary judgment (Order 12 r23) — Meaning of 'Court' — Registrar's powers (Order 25) — Final vs interlocutory relief — Sworn statement formalities (Order 18 r7(5)(c),(d)) — Leave required to use defective statement.
28 February 2018
Applicants' false imprisonment and negligence claims failed where respondent lacked knowledge of an injunction and could not reasonably foresee arrests.
Civil liability – False imprisonment – Requirement that detention be commenced by defendant or by his orders – Negligence – Duty of care, breach and causation – Foreseeability – Effect of intervening police discretion – Notice and timing of injunctive orders.
28 February 2018
Claimants failed to prove false imprisonment, malicious prosecution or defamation; defendant had reasonable cause to report alleged theft.
Tort — False imprisonment — Liability for reporting to police; Malicious prosecution — requirement of termination in favour and absence of reasonable and probable cause and proof of malice; Defamation — publication or conduct; Acquittal does not automatically negate reasonable cause for prosecution.
28 February 2018
Adultery established on balance of probabilities via call logs and witness evidence; plaintiff awarded damages and costs.
Family law – Adultery – proof by circumstantial evidence (call/text logs and witness admission) – damages for loss of consortium and humiliation – default judgment permitted where defendant absent.
20 February 2018
Claimant who operated machinery without authorization failed to prove employer negligence; claim dismissed with costs.
Personal injury – Employer negligence – Duty of care – Unauthorized operation of workplace machinery – Burden of proof on claimant – Credibility of witnesses – Causation and remoteness of damage.
19 February 2018
Driver held negligent and insurer liable to policy limits; plaintiff awarded costs and ordered to seek damages assessment.
Delict/Negligence – duty of care, breach and causation – road traffic accident liability; Insurance law – insurer liable to extent of policy cover; Assessment of damages and costs.
19 February 2018
Failure to meet procedural prerequisites led the court to stay, rather than dismiss, the judicial review hearing.
Civil procedure – premature setting down of matter – failure to file defences – absence of scheduling conference – alleged improper commencement and joinder – stay of judicial review proceedings.
9 February 2018
Assessment of personal-injury damages: quantum fixed for pain, loss of amenities and disfigurement; special claims partly awarded; earning-capacity claim dismissed.
Personal injury — Assessment of damages — Pain and suffering; Loss of amenities of life; Disfigurement; Special damages require pleading and proof; Loss of earning capacity — insufficient evidence.
6 February 2018
January 2018
Appeal dismissed: lower court's adverse-possession finding upheld; inheritance statute inapplicable where not pleaded.
Land law – adverse possession – uninterrupted occupation and use for over 12 years – limitation statute; Civil procedure – evaluation of evidence and credibility; Pleadings – court confined to issues raised; Deceased Estates Act not applicable where inheritance not pleaded.
30 January 2018
Appeal dismissed: adverse possession and trial court credibility findings upheld; inheritance law not considered absent pleading.
Land dispute – encroachment – credibility of evidence and assessment of witnesses; Adverse possession – uninterrupted use exceeding 12 years; Limitation Act principles; Pleadings – court confined to issues raised; Deceased Estates Act not applicable where inheritance not pleaded.
30 January 2018
Plaintiffs entitled to general damages for slander; exemplary damages refused for lack of malice or profit motive.
Defamation (slander) – assessment of damages – general (compensatory) damages awarded for reputational injury; no special damages proved – exemplary damages inappropriate where publication not shown to be profit-driven, malicious or recklessly false; vulgar insulting language may not constitute defamation against men.
22 January 2018
Court granted a three-month extension of a freezing directive under s.23(5) after defendants failed to attend the hearing.
Financial Crimes Act 2017 s.23(5) – Freezing directive – Application for extension – Inter partes hearing – service on defendants and absence of counsel – discretion to extend freezing order.
19 January 2018
Court held management fees non-exempt under DTAs; UK treaty applied as Netherlands entity lacked substance; appeal dismissed.
Tax law – Double Taxation Agreements – management fees not part of industrial or commercial profits; treaty interpretation – literal where wording is clear; residence/substance – sham/substance-over-form; representative taxpayer under Sections 77–78 Taxation Act; interest under Section 105(6) – arithmetic progression, final rate applies to whole period.
16 January 2018
Assessment of damages after a road accident: quantum for pain, suffering and loss of amenities based on medical evidence.
Assessment of damages – personal injury after road traffic accident – quantification of pain and suffering and loss of amenities – reliance on medical reports and viva voce evidence – application of restitutio in integrum – use of comparative awards adjusted for currency devaluation.
10 January 2018
The claimant awarded MK400,000 for pain, suffering and disfigurement after a workplace thumb injury; none for loss of amenities.
Personal injury — assessment of damages — default judgment on liability — evaluation of medical report versus oral evidence — awards for pain and suffering and disfigurement — no award for loss of amenities absent evidence — guidance from comparable awards and restitutio in integrum.
5 January 2018
Court set aside ex parte stay, ordered judgment executed, finding appeal would not be rendered nugatory; costs to applicant.
Civil procedure – stay of execution – setting aside ex parte stay – whether execution would render appeal nugatory – credibility of affidavit/supporting documents – costs.
1 January 2018