High Court of Malawi Civil Division - 2023

43 judgments

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43 judgments
Citation
Judgment date
December 2023
Stay pending appeal continued because impecuniosity was not proven and only quantum was under appeal.
Civil procedure – Stay of execution pending appeal – Appeal concerned only quantum – Burden on applicant to prove appeal would be nugatory by demonstrating impecuniosity at time of application – Procedural non-compliance with issuance formalities distinguished where court had previously fixed hearing date.
15 December 2023
Court awarded two months’ pay per year plus statutory severance, included certain fringe benefits, and ordered refunds and a 10% devaluation boost.
Employment law – unfair dismissal – assessment of compensation – application of s.63(4) and (5) Employment Act – duration of service as primary factor; wages definition – inclusion of fringe benefits (airtime, milk, sugar, fuel, housing) and exclusion of employer pension/medical contributions for severance; mitigation of loss not applied as statutory requirement; failure to lead evidence precludes assessment of salary arrears.
4 December 2023
Regulator acted ultra vires by treating subscription-management provider as a tariff-setting broadcaster; committee hearing was procedurally fair.
Communications law – Tariff regulation (s.74(1)) – Distinction between subscription broadcasting and subscription management services – Scope of licence – Ultra vires review – Delegation to committees (s.15) – Procedural fairness of regulatory enforcement hearing.
1 December 2023
The applicants’ non-consultation before redundancy violated fair labour practices; the SCA precedent was held per incuriam.
Labour law – Retrenchment/redundancy – Requirement to consult employees – Fair labour practices (Constitution s31) – Employment Act s57 and s61(2) – ILO Convention 158 (arts 13–14) – Per incuriam decision (Mkaka One) – Remedy: compensation assessment.
1 December 2023
October 2023
Court refused oral amendment to cure a jurisdictional omission, dismissed the amendment application and awarded costs to the respondents.
Civil procedure — Interlocutory applications — Oral applications permitted under Order 10 rule 2(2) — Amendment of applications — Jurisdictional provision (section 23 Courts Act) omitted — Court will not permit amendment that effectively overturns prior ruling — Costs awarded — Leave to appeal refused.
27 October 2023
Court refused dismissal for want of prosecution and ordered defendant’s lawyers to pay the applicant’s costs personally.
Civil procedure — dismissal for want of prosecution (Order 12 r54) — burden of proof — admissible court file evidence — scheduling conference documents — costs — personal liability of legal practitioners.
24 October 2023
Wrong procedural regime and incurable procedural irregularities led to dismissal of the plaintiff’s action; leave to appeal granted.
Civil procedure – transitional application of rules – 2017 Civil Procedure Rules do not apply to actions commenced before 3 October 2017; Rules of the Supreme Court govern. Procedural irregularity – incurable hybrid use of rules, failure to follow mandatory mediation, improper addition of party – grounds for dismissal. Application to dismiss for want of prosecution must be brought under applicable rules.
18 October 2023
August 2023
Whether default judgment and order for allocation of alternative land are proper despite defective process and Government's failure to defend.
Default judgment against Government; valid service on Attorney General; procedural irregularities not fatal; court can order allocation of alternative land; public interest in protecting educational facilities; compensation governed by Lands Acquisition and Compensation Act.
30 August 2023
July 2023
Offer of lease alone is insufficient for ownership; procedural revocation failure by land authority gives rise to damages against the State.
Land law – offer of lease vs. registered title; Registered Land Act – requirement of registration for leasehold rights; Possession and trespass – possession indicators vs. lawful authority to enter; Town and Country Planning Act – revocation procedure, notice and compensation; Civil procedure – originating summons responses must be by affidavit; State liability for administrative procedural failure.
14 July 2023
10 July 2023
Assessment of wrongful-death damages: valuation of loss of expectation of life and dependency with inadequate income evidence.
Wrongful death — Assessment of damages — Loss of expectation of life — Loss of dependency — Multiplicand and multiplier method — Use of minimum wage where income evidence lacking — Special damages and costs.
4 July 2023
Applicant’s rush to appellate court was premature; lower court’s decision to hear matter inter partes was within its CPR case-management discretion.
Administrative law – judicial review – leave to apply and interim injunction – ex parte v inter partes hearings – case management discretion under CPR – balance of convenience and public interest in stays of administrative decisions.
4 July 2023
June 2023
Assessment of damages for retained surgical pack causing prolonged injury; infertility claim not established by medical evidence.
Medical negligence – retained surgical pack after caesarean – prolonged infection and multiple surgeries – assessment of quantum for pain and suffering, loss of amenities and disfigurement – inability to prove infertility without medical evidence – ex parte assessment after strike‑out of defence – reliance on comparable precedents and consideration of currency devaluation.
28 June 2023
High Court lacks first-instance jurisdiction over customary land disputes; interlocutory injunction and claim dismissed, no costs, leave to appeal refused.
Customary land — Appellate jurisdiction of High Court under s49 Customary Land Act and Reg 76 — First-instance customary land disputes to customary tribunals — Interlocutory injunction inappropriate in wrong forum — Legal Aid: no costs against legally-aided person — Leave to appeal refused.
26 June 2023
A statutory public corporation was held to be protected from seizure-and-sale enforcement under Order 34; the sale and seizure was stayed.
:[
16 June 2023
Default judgment refused due to incurable procedural defects and lack of jurisdiction in a customary land dispute.
Civil procedure – Default judgment – Proof of service and supporting sworn statements – Procedural irregularities (undated/unsigned summons) – Jurisdiction – Customary land disputes and the Customary Land Act 2016 – Effect of subordinate court orders and parties – Costs discretion.
15 June 2023
May 2023
Claimant proved contractor’s negligence for failing to erect roadwork warning signs, causing her husband’s fatal accident.
Negligence — duty of care of road contractor — failure to erect warning signs at roadworks — causation of fatal accident — burden and standard of proof — failure to call material witnesses — costs awarded to successful claimant.
29 May 2023
Applications for stay and enlargement of time dismissed as premature and incompetent for lack of jurisdiction; costs awarded to respondent.
Civil procedure — stay of execution — Applicant must first apply to court below (Order I r.18); stay exceptional and discretionary; Enlargement of time — where order made in chambers leave to appeal required (s.21 SCA Act); Appeals premature before assessment of damages — inchoate judgment; Wrong procedural provision renders application incompetent.
19 May 2023
Claimant failed to show abuse of prosecutorial discretion; permission for judicial review and stay denied.
Judicial review — prosecutorial discretion — rare and extreme circumstances required to intervene — abuse of process and mala fides — threshold for permission to apply for review.
19 May 2023
16 May 2023
12 May 2023
Absence from mediation requires sworn proof of good cause; court adjourned proceeding but ordered defendants to pay attendance costs.
Civil procedure – mediation – defendant's failure to attend – need for sworn evidence to establish good cause – adjournment versus striking out – costs for claimant's attendance.
5 May 2023
Default-judgment application dismissed where land dispute raised deceased-estate issues and procedural proof and identity requirements were unmet.
Default judgment; Order 12 (2017 Rules) — requirements for applications for recovery/possession of customary land; jurisdictional limits where deceased estate/inheritance issues arise; proof of service and identity; requirement to serve personal representative; role of Customary Land Act dispute mechanisms.
4 May 2023
Whether an insurer is liable where the policyholder sold the insured vehicle to the tortfeasor before the accident.
Motor vehicle accident — Admission of liability by tortfeasor — Insurer liability — Effect of insured’s sale of vehicle on policy coverage — Issue referred for trial.
2 May 2023
Relying on errors in the cause list does not justify failing to attend a court-ordered mediation without a reasonable explanation.
Civil procedure — Mediation — Formal notice (Form 14) versus cause list — Failure to attend mediation — Restoration of dismissed action — Requirement of reasonable explanation.
2 May 2023
2 May 2023
April 2023
Employer vicariously liable and breached statutory safety duties; claimant awarded damages and costs.
Employer duty of care; vicarious liability for employee's negligence; breach of Occupational Health, Safety and Welfare Act (s.13); failure to call material witness and to produce maintenance records; contributory negligence considered.
26 April 2023
Whether a Registrar may restore a defence struck out under Order 13(6)(2) or must refer the issue to the Judge.
Civil procedure — Mediation — Order 13(6): distinction between dismissal of claim and striking out defence; Registrar's powers under Order 25 — scope, delegation by Judge, and appealability; referral to Judge under Order 25(2) where jurisdictional uncertainty exists.
19 April 2023
Registrar refers application to Judge, holding restoration of a struck-out defence under Order 13(6)(2) raises jurisdictional ambiguity.
Civil procedure – mediation – strike out of defence for non-attendance – restoration under Order 13(6)(2) – distinction between "dismiss" and "strike out" – Registrar's jurisdiction under Order 25 – referral to Judge – appealability of Registrar decisions when authorised.
19 April 2023
Court set aside stay and dismissed appeal for want of prosecution due to inordinate delay and abuse of process.
Civil procedure – delay and want of prosecution – Inordinate and inexcusable delay as abuse of court process – Stay of execution set aside – Dismissal of appeal under Order 12 Rule 54(1) – Costs awarded to successful party.
18 April 2023
March 2023
Assessment of damages for two accident victims: awards for general damages, nominal future loss due to insufficient income proof.
Damages — Personal injury; assessment of quantum for pain and suffering, loss of amenities and disfigurement; loss of earnings and earning capacity — proof of pre-accident income and use of multiplicand/multiplier — nominal awards where income evidence lacking.
31 March 2023
Court corrected procedural error by granting an enforcement hearing order and requiring direct service on the enforcement debtor before the hearing.
Civil procedure – Enforcement hearing order under Order 28 r.5 – Distinction between enforcement hearing order and notice of examination of judgment debtor – Service requirements where debtor or independent witness absent (seven days) – Power to grant enforcement hearing order despite procedural error.
27 March 2023
A restoration application in Chambers succeeds if a party reasonably explains absence, acts promptly, and shows arguable prospects of success.
Civil procedure — Restoration of proceedings heard in Chambers — Inherent jurisdiction and Orders 1 r.5, 10 r.5 — Requirements: reasonable explanation for absence, promptness, reasonable prospect of success — Prejudice to be considered — Service and chamber practice.
27 March 2023
Permission granted to judicially review university admission decision; preliminary objection on defendant and service dismissed.
Administrative law — Judicial review; procedural fairness and legitimate expectation in university admissions; delegated authority of selection committees under the University of Malawi Act; service of process and proper defendant in judicial review proceedings; interim relief considerations.
10 March 2023
February 2023
First offenders convicted of misuse of public office and influence received three-year sentences suspended for two years due to no loss and mitigating factors.
Corruption offences – Misuse of public office (section 25B(1)) – Influencing public officer (section 25(2)) – Sentencing: breach of trust, planning, no actual loss, first offenders – Suspension of sentence under sections 339 and 340 Criminal Procedure and Evidence Code.
27 February 2023
Permission granted to judicially review a statutory appointment; stay refused pending substantive determination.
Administrative law – Judicial review – Legality and rationality of public appointments – Whether appointment authority lies with President or Minister – Requirement that appointment be from serving public service members – Retirement age under Public Service Act – Standing to seek judicial review – Discretion to grant stay pending review.
17 February 2023
January 2023
Application for stay under Order 28 r48 was procedurally incompetent absent an existing enforcement order; applicant given leave to refile.
Civil procedure – Stay of execution pending appeal – Order 28 rule 48 requires an existing enforcement order – prerequisites for stay: serious issue, inadequate damages, status quo, relative strength of case – procedural competence.
27 January 2023
Court refused to stay compensation assessment pending appeal, holding inchoate liability-only judgments are not suitable for piecemeal appeals.
Civil procedure — Stay of proceedings — Whether assessment of compensation should be stayed pending appeal — Inchoate judgments (liability without quantified damages) not appealable — Jurisdictional objections and choice of assessing officer do not necessarily warrant suspension — Protecting effective remedies and avoiding piecemeal appeals.
25 January 2023
Dismissal without a fair hearing violated constitutional procedural rights; damages awarded, reinstatement impracticable.
Administrative law – right to lawful and procedurally fair administrative action (section 43) – audi alteram partem; Employment law – unfair dismissal for lack of fair disciplinary process; Remedy – damages where reinstatement impracticable; Costs follow the event.
24 January 2023
Permission to seek judicial review denied where applicant failed to establish an arguable case or show ownership of impounded timber.
Administrative law — Judicial review — Leave to apply for judicial review — Applicant must show an arguable case; insufficient, inconsistent documentary evidence; section 42(2)(b) inapplicable where applicant was not arrested.
18 January 2023
Road obstruction by a driver caused the collision; the insurer was held liable and damages will be assessed.
Motor vehicle accident — Road obstruction as breach of duty — Foreseeability and causation — Insurer vicarious/liability for insured driver — Assessment of damages and costs.
13 January 2023
Court awarded K22,000,000 for fatal accident: K20M to estate, K2M to injured claimant; special damages denied.
Personal injury — Fatal road accident — Damages: loss of expectation of life; loss of dependency (calculated via minimum wage × 12 × remaining years); general damages for pain and suffering; special damages and disfigurement not proved; costs to claimants.
5 January 2023
Assessment of damages for a child’s death: loss of expectation of life, dependency and survivor’s pain and suffering.
Damages – wrongful death of a child – loss of expectation of life; loss of dependency – multiplier method using minimum wage and two‑thirds rule; general damages for pain and suffering; refusal to award unproven special damages; costs awarded to claimants.
5 January 2023