High Court of Malawi Criminal Division

143 judgments

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143 judgments
Citation
Judgment date
July 2019
Applicant failed to prove prohibited post‑campaign activity or tally irregularities that affected the election result; petition dismissed.
Electoral law – election petition under s100 – alleged post‑campaign campaigning and inducements – alleged tally/result irregularities – burden and standard of proof (balance of probabilities) – petitioner failed to prove irregularities affected result – petition dismissed.
9 July 2019
June 2019
12 June 2019
May 2019
17 May 2019
March 2019
7 March 2019
September 2018
Burden-presumption in theft by public servant applies; conviction upheld and custodial sentence increased to 24 months.
Criminal law – Theft by public servant – Burden of proof – Legal presumption under s.283(1) Penal Code once employment, custody and inability to account are proved – accused must rebut on balance of probabilities – sufficiency of evidence – aggravated theft and custodial sentence.
12 September 2018
August 2018
Bail after statutory custody time-limit is not automatic; court refused bail due to brutality and strong inculpatory evidence.
Criminal law — Bail — custody time-limit under s161G — interplay with constitutional ‘interest of justice’ under s42(2)(e) — factors: seriousness of offence, strength of prosecution, risk of flight or tampering — refusal of bail in a case of brutal murder with inculpatory confession.
31 August 2018
July 2018
Conviction and 42-month sentence for theft by servant upheld where appellant had sole control and failed to account.
Criminal law – Theft by servant – Proof where stock or cash shortage – application of Nguwo factors (size of deficiency, control/access, alternative causes, enrichment) – Documentary delivery notes and failure to report – Sentencing: Rep v Missiri guidance; appellate interference only if sentence excessive.
18 July 2018
June 2018
Circumstantial evidence of custody and control upheld conviction for theft by servant; excessive sentence noted but confirmed as served.
Criminal law – Theft by servant – Circumstantial evidence sufficiency – Custody and control of keys/cash – Standard of proof – Sentence excessive but confirmed due to time served.
22 June 2018
Conviction for breaking into a building confirmed; manifestly excessive 7-year sentence reduced to 4 years on review.
Criminal law — s.311 Penal Code (breaking into a building and committing a felony) — confirmation of conviction — sentencing on review — manifestly excessive sentence — mitigation (first offender; change of plea) v. aggravation (security guard breach of trust; night; premeditation; financial gain) — sentencing guidelines applied — sentence reduced from 7 to 4 years.
8 June 2018
Convictions confirmed; court could not vary manifestly inadequate/excessive sentences already served.
Criminal law – Confirmation of convictions – Sentencing – Manifestly inadequate and manifestly excessive sentences – Inability to vary sentences already served – Breach of trust as aggravating factor; sentencing guidelines for burglary and theft.
8 June 2018
Convictions confirmed, but consecutive sentences set aside and made concurrent, reducing cumulative term and prompting immediate release.
Criminal law — Theft of cattle — Sentencing — Concurrent versus consecutive sentences — Offences committed in a single transaction — Sentencing guidelines and mitigation for first-time guilty plea — Excessive cumulative sentence set aside.
8 June 2018
Convictions confirmed but consecutive, excessive sentences reduced and ordered to run concurrently, yielding a four-year term.
Criminal law – housebreaking and theft – sentencing – concurrent versus consecutive sentences – requirement to give reasons for consecutive sentences – mitigation (youth, first offender, plea) – manifestly excessive sentence – review and alteration of sentence.
7 June 2018
May 2018
Conviction confirmed; housebreaking and theft sentences reduced after weighing aggravating and mitigating factors.
Criminal law — Confirmation of convictions — Housebreaking (s 309 Penal Code) and theft (s 278) — Sentencing principles and Magistrates' Court guidelines — Aggravating and mitigating factors — Reduction of manifestly excessive sentences.
21 May 2018
Conviction for buggery confirmed; inadequate 12‑month sentence reluctantly upheld because review delay led to the prisoner’s release.
Criminal law — Buggery (s 153(a) Penal Code) — Conviction confirmed; sentence manifestly inadequate but not increased due to delay and prisoner’s release — review procedure and production orders.
11 May 2018
Non‑compliance with the Banker's Books Evidence Act rendered crucial bank evidence inadmissible, making theft and money‑laundering convictions unsafe.
Criminal law – theft and money laundering – liability of directors for corporate offences (s24 Penal Code) – duplicity in charging predicate and laundering offences – admissibility of public records – Banker's Books Evidence Act ss 4–5 compliance required for bank documents.
7 May 2018
March 2018
Conviction for defilement affirmed; custodial sentence set aside and substituted with reformatory placement due to offender’s age.
Criminal law – Defilement – proof of victim’s age – evidentiary burden shifts once prosecution proves age; Child offenders – sentencing – custodial sentence excessive for child; Child Care, Protection and Justice Act 2010 – reformatory disposition and review.
20 March 2018
February 2018
Robbery conviction and consecutive sentence upheld; confession and warrantless search lawful; eight-year term reduced to three years IHL.
Criminal law – Robbery – elements and corroboration; Admissibility of caution statements – corroboration and voluntariness; Arrest and search – s24A(1) warrantless search in presence of arrested person; Defence witnesses – securing attendance and withdrawal; Sentencing – consecutive sentences and mitigation for youth.
13 February 2018
January 2018
Provocation, youth, first-offender status and a guilty plea justified a ten-year manslaughter sentence despite knife wounds.
Criminal law – Manslaughter – Sentencing discretion under s211 – Maximum life reserved for worst cases – Aggravating factor: use of knife; Mitigation: guilty plea, provocation, youth, first offender.
26 January 2018
Failure to conduct a voir dire for a 15-year-old complainant led to exclusion of evidence and allowed appeal.
Criminal law – defilement; child witness competence – requirement for voir dire under Oaths, Affirmations and Declarations Act; meaning of 'immature age' and interaction with child-related statutes; exclusion of evidence where voir dire absent; failure to prove case beyond reasonable doubt; retrial and double jeopardy.
24 January 2018
Court granted bail to a homicide accused overstaying on remand, imposing strict surety, reporting and travel‑restriction conditions.
Bail — application under s12 Bail Guidelines Act, s118 Criminal Procedure and Evidence Code and s42(2)(e) Constitution — accused charged with homicide and long remand — grant of bail in interest of justice — conditions: cash deposit, bonded sureties, periodic police reporting, surrender of travel documents, leave required to leave village.
19 January 2018
Failure to comply with s.251 proviso invalidates a guilty plea; retrial ordered and sentence to be reconsidered.
Criminal procedure – guilty plea – proviso to s.251 – court must ascertain accused understands nature and consequences of plea; admission of facts insufficient – non‑compliance warrants retrial; sentence review – manifest excessiveness where guilty plea and recovery of property.
19 January 2018
3 January 2018
December 2017
Conviction for intimidation confirmed; 60‑month custodial sentence reduced to 24 months as manifestly excessive.
Criminal law – Intimidation (s.88 Penal Code) – sentencing principles – manifestly excessive sentence – requirement to indicate applicable statutory maximum – consideration of aggravating and mitigating factors – substitution of sentence on review.
18 December 2017
18 December 2017
November 2017
Accused discharged under s77 CP&EC after prosecution discontinued proceedings; bail and recognizances discharged.
Criminal procedure — Prosecution discontinuance — Discharge under s 77 Criminal Procedure and Evidence Code — Effect on bail and recognizances — Pronouncement in open court
10 November 2017
June 2017
12 June 2017
April 2017
Court reduced custodial sentences for cattle theft and shortened juvenile’s probation due to mitigating factors.
Criminal law – Sentencing – Theft of cattle – Review of manifestly excessive sentences – First offenders and juveniles – Mitigating factors (recovery of property, guilty plea, first‑offender status) outweighing aggravating factors – Reduction of custodial terms and probation.
21 April 2017
January 2017
27 January 2017
6 January 2017
5 January 2017
4 January 2017
4 January 2017
4 January 2017
April 2016
Court confirmed custodial sentences for the appellant found with protected species and an unlicensed firearm as not manifestly excessive.
Wildlife law – possession of protected species – sentencing; Firearms law – possession of prohibited weapon and ammunition; Sentencing – custodial versus non-custodial for first offenders; Appellate review – manifestly excessive test.
8 April 2016
July 2013
Limitation does not bar claims alleging criminal insider trading or fiduciary breaches; each share trade is a separate transaction.
Securities law – insider trading (S.49) – criminal offence; Limitation Act (s.4) – inapplicable to alleged criminal conduct and fiduciary breaches; continuous transaction rule – each trade a separate cause of action; Companies Act – shareholder remedies; Malawi Stock Exchange listing rules.
13 July 2013
October 1994
Court affirms 18-month sentence for bicycle theft, stressing guilty plea and voluntary restitution as key mitigators.
Criminal law – Theft – Sentencing – Mitigation: guilty plea, voluntary restitution, and family obligations; plea change diminishes mitigation; sentence affirmed.
27 October 1994
Conviction for theft by a public servant quashed due to insufficient evidence and lack of proper stock/accounting.
Criminal law – theft by public servant – failure to account – insufficiency of evidence – lack of stock records and alternative access to store-room – conviction quashed on review.
20 October 1994
July 1994
A public servant who cannot account for cash exhibits is presumed to have stolen them unless the presumption is rebutted.
Criminal law – Theft by public servant – Section 283(1) presumption where public officer fails to account – ownership of cash exhibits – damaged-safe defence – auditors' documentary corrections – mandatory minimum sentence.
22 July 1994
June 1994
Appeal against theft conviction upheld; sentencing disparity and prior convictions considered, sentence described as somewhat harsh.
Criminal law – Theft from a person – Appeal against conviction and sentence – Appellate review of trial court credibility findings – Sentencing: relevance of previous convictions and undue disparity between co-accused sentences.
19 June 1994
A 22-year-old first offender’s 12-month imprisonment was set aside and replaced by a K2,000 fine (or six months' default).
Criminal law – Dangerous Drugs – Illegal possession of Indian hemp (144.10g) – sentencing – mitigating factors (youth, first offender, guilty plea, personal consumption) – substitution of custodial sentence with fine.
15 June 1994
April 1994
Appeal allowed: absence of Inspector General's order did not void prosecution, but proceedings should have been stayed under s.161.
Criminal law — Prosecution of police officers — Police Act s.47 and s.39 — written Inspector General order not required for non-disciplinary offences; discretion to stay/terminate proceedings under s.161 where disciplinary context and mitigating circumstances justify relief.
22 April 1994
March 1994
Conviction for theft by servant affirmed where audit records, witness testimony and confession established the missing funds.
Criminal law — Theft by servant — Reliance on audit documents, shop manager testimony and confession to prove missing takings — Alternative explanations failing to create reasonable doubt.
7 March 1994
February 1994
8 February 1994