High Court of Malawi Civil Division - 2022

71 judgments

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71 judgments
Citation
Judgment date
December 2022
Assessment of severe leg injuries: court awarded K29,000,000 (less prior K7,750,000), balance K21,250,000 payable in 45 days.
Personal injury — Assessment of damages — Pain and suffering, loss of amenities, disfigurement, loss of future earning capacity, nursing care — Hearsay inadmissibility of medical reports not tendered by authors — Use of pictorial evidence and court observation — Multiplicand/multiplier method for future loss — Restitutio in integrum and proportionality.
24 December 2022
Court reduced taxed costs from MK255.7m to MK70.9m; required evidential support, proportionality, and awarded instruction fee to the NGO.
Civil procedure — Taxation of costs — Order 31 CPR — standard basis: reasonableness and proportionality; evidence required for fee earners and timesheets; instruction fees payable to instructed firm; expert fees require receipts/agreements; review where taxing officer erred or was unreasonable.
20 December 2022
The claimant vacated an ex parte suspension after defendants failed to draw or serve the formal order.
Judicial review – ex parte suspension of enforcement – failure to draw up and serve formal order – Order 23 Rule 2(3)(a) – service by WhatsApp insufficient – bad faith – overriding objective and equal footing – application to vacate granted.
9 December 2022
Whether a statutory law society may curtail members' freedom of association requires full trial and constitutional certification.
Constitutional law – freedom of association of lawyers – declaratory relief – suitability for summary disposal; Professional regulation – scope of regulator’s powers over members; Competition law – alleged monopoly by specialist bar associations; In-house lawyers – entitlement to perform restricted legal work under section 31(1).
8 December 2022
Application for summary declaratory relief to restrict lawyers' association rights declined; constitutional issues referred to multi-judge panel.
Administrative law and professional regulation – Declaratory relief – Freedom of association – Whether a statutory law society may curtail members' association rights – Summary disposal standard – real prospect of defence – Competition law and restricted legal work issues.
8 December 2022
Court refused summary declarations to restrict lawyers' association rights, referring constitutional questions to a multi-judge panel.
Constitutional law — freedom of association of lawyers — limits by regulatory law society; declaratory relief — justiciability; summary disposal — real prospect of defence required; in-house lawyers and restricted legal work; competition concerns in specialist legal associations.
8 December 2022
November 2022
The court refused the applicant's interlocutory injunction, preserving the respondent's possession pending final determination.
Interlocutory injunctions – land disputes – adequacy of damages – status quo – balance of convenience – delay and long-standing possession.
24 November 2022
Registrar recused and referred the enforcement application to the judge after counsel's intimidating, unprofessional conduct raised an appearance of bias.
Recusal — Registrar's referral to judge under Order 25 CPR 17 — Objective test for appearance of bias — Counsel's professional conduct and duty to court — Judicial independence and administrative authority of Registrar.
21 November 2022
Claimant's failure to comply with Registrar's order led to automatic dismissal for want of prosecution; no costs awarded.
Civil procedure – want of prosecution – failure to comply with Registrar's directions – automatic dismissal for inexcusable delay – costs discretion.
16 November 2022
Application to vary preservation order for living and legal expenses dismissed for failure to prove need and inadequate disclosure.
Financial Crimes Act – preservation orders – variation for reasonable living and legal expenses – statutory criteria under ss.70–71 – disclosure on oath – admissibility and weight of FIA financial analysis and bank statements – balancing preservation against hardship.
3 November 2022
October 2022
An oral stay of the recusal ruling was disallowed for procedural non-compliance, prematurity, lack of merits, and counsel misconduct.
Civil procedure – stay pending appeal – oral application – Order 10 r.9 CPR; Inherent jurisdiction – limited role where statute governs; Leave to appeal required for judgments in chambers (s.21 SCA Act); Duty of candour – counsel misconduct; Costs awarded.
31 October 2022
A dependant suing (not as executor) is limited to Part I damages; court uses minimum-wage multiplicand and Treasury Note discount rates.
Statute Law (Miscellaneous Provisions) Act – Part I survival actions – loss of dependency; claimant not executor limited to Part I remedies; assessment of dependency damages — multiplicand from minimum wage where earnings unproved; split pre-trial/post-trial losses; use of Malawi Treasury Note yields as discount rate.
31 October 2022
Judicial review permission denied where statutory appeal to the Police Service Commission remained unexhausted; demotions upheld for now.
Administrative law – judicial review – permission stage – requirement to exhaust statutory alternative remedies (appeal to Police Service Commission) – timeliness within three months – proper naming of statutory disciplinary bodies – demotion as review decision by National Police Disciplinary Committee.
28 October 2022
A properly executed release discharges further claims and estops the releasor unless set aside for fraud or misrepresentation.
Civil procedure – Release and Discharge Agreement – Binding effect of a properly executed release – Estoppel by release – Relief to set aside a release requires strong evidence of fraud, misrepresentation or mutual mistake; illiteracy or private negotiations without counsel insufficient without clear proof.
25 October 2022
High Court claim dismissed as abuse of process where identical Magistrate’s Court proceedings and consent order existed.
Civil procedure – abuse of process – multiplicity of proceedings – res judicata – consent order effect – inherent power to dismiss frivolous or vexatious actions – motor vehicle personal injury claim.
4 October 2022
Applicant's revision for failure to admit a written contract dismissed; remedy available by appeal; record remitted.
Civil procedure — Supervisory and revisionary jurisdiction (s26 Courts Act) — Duty of trial courts to guide unrepresented parties on adducing documentary evidence — Review barred where appeal lies and was not pursued (s27 Courts Act) — High Court's power on appeal to call additional evidence (s22(d)).
4 October 2022
Oral recusal application lacking legal basis, service, sworn evidence, and cogent proof of bias was dismissed with costs.
Recusal — Judicial impartiality — Appearance of bias assessed by the fair‑minded, informed observer test — Requirement of cogent evidence — Procedural compliance under CPR (Order 10) essential for interlocutory applications — Dismissal in limine for procedural defects.
3 October 2022
The claimant failed to prove a grant from the prior owner; claim for possession dismissed for insufficient evidence.
Property — proof of grant — documentary and oral contradictions; evidentiary weight of survey plans; burden and standard of proof in civil land disputes; failure to produce original documents and corroborating witnesses; claim for summary possession dismissed.
3 October 2022
September 2022
Employer liable for false imprisonment and malicious prosecution; defamation unproven and counterclaim dismissed.
False imprisonment – employer-instigated arrest – procurement of police arrest by company officers; Malicious prosecution – absence of reasonable and probable cause; Defamation – need to plead and exhibit defamatory words/publication; Employer counterclaim – burden to prove employee’s liability for missing stock and cash; Police discretion vs. procuring arrest by private party.
16 September 2022
Police arrested and prosecuted the claimant on their own investigations; the defendant merely reported the fraud and is not liable for false imprisonment or malicious prosecution.
Tort — False imprisonment; malicious prosecution; distinction between making a charge and giving information to Police; civil liability where private party procures arrest — evidence required to show arrest was at party’s instance.
16 September 2022
Workplace fall caused by claimant’s failure to take reasonable care; employer not liable under statutory or common‑law duties.
Occupational Safety, Health and Welfare Act s.13 employer duty; s.18(a) employee duty to take reasonable care; negligence — employer v employee liability; res ipsa loquitur inapplicable where cause known; amendment of pleadings post‑closure permissible if no uncompensable prejudice.
16 September 2022
Court declined to stop defendants' existing use of disputed estate land but barred further development pending final determination.
Interim injunctions — serious question to be tried — adequacy of damages — balance of convenience — preservation of status quo in land disputes arising from deceased estates.
13 September 2022
Contested disputes over entitlement to deceased estate assets require a full trial, not determination on affidavits.
Probate — Distribution of deceased estate — Contentious factual disputes — Affidavits insufficient — Referral to trial — Exemption from mediation — Alleged matrimonial property, land and maize mill disputes.
13 September 2022
Employer liable for security guard's injuries due to unsafe system of work and inadequate training/equipment.
Employer's duty of care – safe system of work – inadequate training and equipment – abandonment during operation – employer liable for injuries – damages to be assessed.
13 September 2022
Whether a certificate of non‑compliance obtained without proper procedural application should be set aside and injunction reviewed.
Civil procedure – interim injunction – requirement to file notice to continue – certificate of non-compliance – procedural prerequisites for obtaining certificate – setting aside certificate – further hearing to determine continuation or discharge of injunction.
4 September 2022
August 2022
Employer exposed trained operator to a faulty, unsafe machine; claimant’s injury caused by employer’s failure to ensure safe workplace.
Occupational safety – employer’s duty to provide safe machinery and protective equipment – machine with faulty sensor and repeated repairs – employer exposure of employee to unsafe working environment – causation and negligence.
29 August 2022
An application to vary a restriction notice was moot after expiry; court refused to grant unpleaded mandatory/declaratory relief.
Corrupt Practices Act s23(1),(3) – Restriction notices – Mootness/overtaken-by-events – Variation of restriction notice – Mandatory/declaratory relief not pleaded – Limits on court making relief beyond the application.
26 August 2022
Renewal of restriction notice upheld: "show cause" requires cogent reasons, not prima facie proof.
Corrupt Practices Act s.23(3) – renewal of restriction notice – meaning of "show cause" – standard: cogent reasons/sufficient information to justify reasonable belief rather than prima facie proof – mootness of appeals – allegations of judicial bias require concrete evidence.
16 August 2022
Claimants failed to prove negligence, statutory breach, nuisance or trespass from quarry blasting; suit dismissed with costs.
Quarrying and blasting — negligence — causation and proof — expert measurement of blast frequency, attenuation and charge — nuisance and trespass — materiality and continuity of interference — statutory duty (Explosives Act; Occupational Safety, Health and Welfare Act) — Rylands v. Fletcher — burden and standard of proof in civil cases.
15 August 2022
Claimants failed to prove quarry blasting caused actionable negligence, statutory breaches, nuisance or trespass; claim dismissed with costs.
Tort — negligence — causation and remoteness in blasting cases; nuisance and trespass — requirement of materially excessive or continuous interference; statutory duty under Occupational Safety, Health and Welfare Act and Explosives Act — proof required; Rylands v. Fletcher and res ipsa loquitur — prerequisites and pleading; evidentiary need for blast measurements (frequency, PPV, attenuation).
15 August 2022
Ex parte judicial-review permission and stay discharged where claimants lacked standing due to material non-disclosure.
Judicial review — permission and interim relief — inherent jurisdiction to vacate ex parte orders; Locus standi — sufficient interest; Material non-disclosure — duty of full and frank disclosure in ex parte applications; Refugee law — status determination and effect of Ministerial rejection; Administrative procedure — phased execution of relocation notice (rural then urban); Costs — awarded where claimants improperly obtained interim relief.
12 August 2022
Court refused to enhance three-year sentence for unlawful wounding of spouse, finding injury medically superficial and not grievous.
Criminal law – Unlawful wounding – Sentencing – Domestic violence – Whether wound amounts to grievous harm or attempted murder – Sentencing guidelines and assessment of injury severity – Youth and first offender mitigation.
4 August 2022
Assessment of damages for fatal school accident: loss of expectation of life and dependency awarded, using minimum wage multiplicand.
Negligence — assessment of damages — fatal school accident; loss of expectation of life; loss of dependency; multiplicand and multiplier; use of minimum wage as multiplicand; one-third deduction; party-and-party costs.
4 August 2022
July 2022
Assessment awarded MK6.8m (plus MK3,000 police report), net MK4,762,100 after 70% defendant liability; medical report cost not proved.
Assessment of damages – non‑pecuniary losses (pain and suffering, loss of amenities, disfigurement) – use of comparable awards and currency adjustment – proof required for special damages – apportionment of liability applied – insurer's policy limit disregarded for lack of evidence.
29 July 2022
Leave denied: claimant’s judicial review was premature for failing to exhaust licence arbitration and internal remedies.
Administrative law — Judicial review — Leave required; alternative remedies/arbitration under licence; Communications Act s74 (tariff regulation) and clause 11.2 (prior approval) — Preliminary findings and procedural fairness — Ultra vires challenge to regulatory inquiry.
25 July 2022
Interlocutory injunction refused where procedural non‑compliance and a registered caution already prevent property disposition.
Civil procedure – Interlocutory injunction – Order 10 r.3 & r.8(1) compliance when applying before proceedings – Registered Land Act s.127(2) – Effect of registered caution preventing disposition – Balance of convenience.
22 July 2022
Assessment of personal injury damages reduced for evidentiary discrepancies and subject to agreed contributory negligence.
Assessment of damages — personal injury — pain and suffering, loss of amenities, disfigurement — reliance on comparable local awards — effect of contributory negligence and inconsistencies in pleadings/evidence on quantum.
7 July 2022
Unchallenged invoices proved special damages; court awarded hiring and repair costs after default judgment.
Assessment of damages — special damages — strict proof required — unchallenged invoices and quotations sufficient to establish quantum — award for hiring and repair costs following default judgment.
7 July 2022
June 2022
Taxation on the standard basis; instruction fee partly allowed, brief fees disallowed, total taxed costs MK30,421,125.
Costs taxation – standard basis assessment – counsel hourly rate – instruction fee allowed; brief fees disallowed – reduction of excessive hours and disbursements – care and conduct uplift.
29 June 2022
Default judgment awarding declarations, injunction and damages for trespass on claimant's leased land; damages to be assessed by Registrar.
Property law – Trespass – Default judgment – Declaratory relief and permanent injunction – Damages to be assessed by Registrar to include inconvenience.
28 June 2022
24 June 2022
Assessment of damages for asbestos exposure: non-pecuniary losses awarded; brain damage and loss of earning capacity not proved.
Personal injury — Asbestos exposure — Assessment of damages — Pain and suffering; loss of amenities; special damages proof; loss of earning capacity — Necessity of medical proof for brain damage and receipts for special expenses.
24 June 2022
Damages assessed after admitted liability; policy-limit evidence improper at assessment; awards based on minimum wage and multiplier.
Assessment of damages – procedure where parties fail to agree after mediation – inadmissibility of policy-limit evidence at damages assessment – representation and binding effect of admissions – computation method for loss of dependency using minimum wage and multiplier.
24 June 2022
Court awarded MK4,810,000 for proven injuries, rejecting unproven traumatic brain injury and unsubstantiated business income.
Road traffic accident — quantum of damages — pain and suffering, loss of amenities, disfigurement — loss of earnings and earning capacity — proof of traumatic brain injury and business income — reliance on comparable awards.
23 June 2022
Assessment of personal injury damages after default judgment: court awards MK12,000,000 for pain, disfigurement and 28% incapacity.
Personal injury — assessment of damages — pain and suffering, loss of amenities, disfigurement — permanent incapacitation assessed at 28% — use of comparable awards — default judgment — quantum and costs.
23 June 2022
The respondent’s five‑year sentence for defiling a 12‑year‑old was manifestly inadequate and increased to 14 years.
Criminal law – Defilement – Sentencing – Starting point of 14 years for victims at the lower end of age spectrum – Review standard for sentences: error in principle/manifestly inadequate or excessive – Aggravating factors: victim age (12), use of force and threats, significant age gap – Mitigation: youth and first offender status insufficient to justify leniency.
23 June 2022
May 2022
A purportedly created village/headmanship must follow consultative procedure and cannot extinguish existing customary land rights.
Chiefs Act – creation and recognition of villages – necessity of consultation with District Commissioner and affected persons; Customary land – use and occupation rights protected; Village headmanship does not extinguish pre-existing land rights; Remedies for trespass require specific, case-by-case proceedings; Mediation exemption considered where dispute involves complex chieftaincy and land issues.
30 May 2022
The Minister acted without jurisdiction and denied the applicant procedural fairness; ministerial and MHC decisions were quashed.
Administrative law — ministerial ultra vires action — Statutory Bodies (Control of Contracts) Act inapplicable — procedural fairness and right to reasons under section 43 — decision quashed.
26 May 2022
Ministerial direction to revoke a lease was ultra vires and procedurally unfair; decision quashed.
Administrative law – Judicial review – Ultra vires ministerial intervention; Statutory Bodies (Control of Contracts) Act inapplicable to lease revocation – Right to lawful and procedurally fair administrative action; audi and reasons – Protection of property rights.
26 May 2022
Sale to the claimant, a foreign national, was void for non-compliance with Land Act; injunction and claims dismissed.
Land law – Sale of private land to non-citizen – Ministerial consent and newspaper publication requirements – Illegality and voidness of contract; interlocutory injunction – serious question to be tried; inadmissibility of irregular sworn statements; remedies for rectification of land register entries.
24 May 2022