High Court of Malawi Family and Probate Division

39 judgments

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39 judgments
Citation
Judgment date
July 2025
Court ordered DNA tests to resolve disputed parentage for estate succession and charged testing costs to the estate.
Family law; succession and inheritance – determination of parentage – DNA testing versus birth certificates as prima facie evidence – standing of interested persons – statutory three-year limit for parentage applications; estate to bear testing costs.
9 July 2025
March 2025
Court denied the applicant’s request to relocate three children to Canada as contrary to their best interests.
Child relocation – best interests of the child; parental capacity and financial stability; continuity and family relationships; compliance with Malawi dual-citizenship law; unilateral registration of minor’s foreign citizenship.
14 March 2025
Respondent awarded 50% shares in matrimonial assets due to non‑monetary contributions and equality‑as‑equity principle.
Matrimonial property – recognition of non‑monetary contributions – beneficial interest; distribution of assets on divorce – equality‑as‑equity principle; intention v contribution test for joint ownership; application of CEDAW and Maputo Protocol.
11 March 2025
January 2025
Leave to appeal and a stay were dismissed as premature and procedurally incompetent because the High Court judgment remained inchoate.
Civil procedure – inchoate judgment – premature leave to appeal – inchoate judgments not appealable; stay of execution – must first apply to High Court where concurrent jurisdiction exists; SCA jurisdiction invoked after refusal by High Court; procedural competency of applications.
22 January 2025
November 2024
Leave to appeal denied to avoid piecemeal, inchoate appeals and to expedite resolution of child custody and relocation issues.
Appeal — leave to appeal — requirement under s.21 Supreme Court of Appeal Act; Inchoate appeals — prohibition on piecemeal appeals; Case management — expediency in child custody disputes; Jurisdiction — relocation application to Chief Resident Magistrate (Centre); Costs — each party to bear own costs.
29 November 2024
April 2024
An informal union cannot be dissolved by divorce; the applicant must seek declaration of marriage by repute and ancillary reliefs.
Constitutional recognition of informal unions; Marriage, Divorce and Family Relations Act ss.12–13; marriage by repute/permanent cohabitation; declaratory jurisdiction to determine existence; ancillary reliefs (custody, maintenance, property) available after court finds such union; divorce proceedings inappropriate to dissolve non-formal unions.
18 April 2024
February 2024
Court continued interlocutory injunction restraining exercise of power of sale pending resolution of alleged fraudulent charge.
Injunctions – interlocutory injunction – American Cyanamid principles – power of sale under Registered Land Act (ss.68,71) – alleged fraud/forgery in charges over estate property – adequacy of damages – uniqueness of land.
22 February 2024
September 2023
30 September 2023
August 2023
Court allowed a limited grant and held a single adult beneficiary applicant may be administrator; criticized improper affidavits and counsel supervision.
Probate—Jurisdiction under DEWIPA—High Court competence for estates above K1,000,000; Letters of administration—single administrator permissible where beneficiaries are adult; Evidence—affidavits must be signed by deponents; Professional conduct—counsel’s supervisory duties and effect of improper commissioning of affidavits.
25 August 2023
High Court may refer apparent perjury arising in civil proceedings to a Resident Magistrate; petitioner’s credibility doubted.
Procedure and criminal referrals in civil proceedings – High Court jurisdiction under s108 Constitution and s12 Courts Act – CPR powers to re-open after trial but before judgment – Appearance of perjury on balance of probabilities – Credibility and weight of evidence – Referral to Resident Magistrate under Penal Code s101.
18 August 2023
18 August 2023
May 2023
16 May 2023
Claimant lacked locus to litigate intestate estate claims without letters of administration; customary marriage invalid due to prior statutory marriage.
Probate and administration — Intestacy — Requirement for letters of administration under DEWIPA to enforce beneficiaries’ rights — Locus standi to sue in estate matters — Validity of customary marriage where prior statutory marriage subsists — Children’s rights and guardianship obligations.
16 May 2023
April 2023
High Court apportions house one-third to appellant, upholds respondent's vehicle ownership, and increases compensation to K1,500,000.
Family law - Matrimonial property division; intention of parties; contributions to land and construction; valuation by independent valuer; vehicle ownership and contribution; compensation for unequal sharing.
24 April 2023
Applicant awarded one-third of the matrimonial house; respondent retains cars; compensation increased to K1,500,000.
Family law – divorce – division of matrimonial property – intention of parties in property acquisition – evidence of contributions; Motor vehicle ownership – custodial acquisition, contributions and use; Compensation – assessment of fair monetary compensation for non-material and economic losses during relationship.
24 April 2023
19 April 2023
19 April 2023
18 April 2023
March 2023
Court set aside a regularly obtained default judgment to allow probate disputes to be decided on their merits.
Civil procedure — Service of summons and default judgment — Order 5 & Order 12 CPR; Setting aside default judgment — Order 12 rule 21 — reasonable cause and meritorious defence; Probate law — Deceased Estate (Wills, Inheritance and Protection) Act — merits to be determined.
6 March 2023
January 2023
A prenuptial agreement cannot override statutory intestacy rights—letters procured on that basis were revoked.
Deceased estates – Intestacy – Prenuptial agreements do not displace statutory intestacy rights; letters of administration revocable under s55 if procured by untrue legal allegation; administrators ordered to account.
27 January 2023
27 January 2023
November 2022
Adoption denied where unsanctioned payments and improper procurement of consent compromised the child’s best interests.
Adoption law – consent and capacity – role of Guardian‑ad‑Litem – prohibition on payments and court sanction – best interests of the child – intercountry adoption safeguards – foreign residence and supervised placement.
18 November 2022
Adoption refused: doubts about informed consent, petitioner’s credibility, inadequate in‑country bonding, and lack of statutory/international safeguards.
Adoption law — Best interests of the child; consent to adoption and revocation; residence and in‑country bonding requirements for foreign adopters; duties and centrality of the Guardian‑ad‑Litem; single male applicants and 'special circumstances'; interim orders and need for Hague Convention safeguards.
11 November 2022
A counsel's affidavit containing factual evidence and legal argument is improper; extension of time for judicial review denied.
Procedure and professional ethics — Counsel swearing affidavits — Factual evidence, legal opinion and argument in counsel's sworn statement — Cross-examination risk — Extension of time for judicial review refused.
7 November 2022
A counsel-sworn affidavit containing facts and legal opinion was improper; the applicant's extension for judicial review was refused.
Civil procedure — Affidavits by counsel — Counsel as deponent and potential witness; risk of cross-examination and conflict — Affidavits should not contain primary factual assertions, personal legal opinions or argument — Judicial review — extension of time.
7 November 2022
September 2022
Whether letters of administration should be revoked where only declared bank funds were administered despite alleged undisclosed assets.
Deceased Estates Act (ss.20, 55) – revocation of letters of administration – misrepresentation of estate value – household belongings – estate duty assessment – fresh letters for unadministered assets.
13 September 2022
June 2022
Court confirms mother's custody on best‑interests grounds; father denied physical access until psychological assessment and counselling.
Family law – Child custody – Best interests of the child paramount – Separate custody hearing desirable but not always required – Parental conduct (abduction, contempt, violence) material to custody and access – Psychological assessment/counselling as precondition to physical access.
24 June 2022
May 2022
Divorce petition dismissed for lack of jurisdiction because the petitioner failed to prove domicile in Malawi.
Family law — Divorce jurisdiction — Domicile versus residence — Domicile of origin v. domicile of choice — Burden of proof — Temporary employment permits insufficient to prove change of domicile — Dependent cross-petition falls away on dismissal of main petition.
27 May 2022
27 May 2022
Disputed house and car were not matrimonial property; respondent held sole beneficial ownership.
Family law – Matrimonial property – Whether assets are jointly held – Beneficial interest requires contributions beyond routine assistance – Intention to hold jointly assessed by conduct and credible evidence – Registration and insurance entries not determinative of beneficial ownership.
27 May 2022
February 2022
Court revoked Letters of Administration, appointed Administrator General, lifted corporate veil to address alleged estate grabbing and ordered audits/accounts.
15 February 2022
January 2022
Decree nisi granted for divorce on cruelty; adultery not proved and statutory compensation unavailable.
Family law — applicable statute for pre‑2015 marriages — MDFRA Part LX only; jurisdiction — domicile of choice; divorce — cruelty standard, condonation and collusion; adultery — insufficiency of suspicion and unauthenticated evidence; compensation not available under Divorce Act.
10 January 2022
May 2021
Divorce granted on cruelty proved; desertion not established; parties to file custody submissions; no costs order.
Family law – Divorce jurisdiction under (repealed) Marriage Act and Divorce Act – Domicile requirement – Cruelty as ground for divorce – Legal test for cruelty (conduct rendering continued cohabitation and conjugal duties unbearable) – Desertion: statutory three-year separation, intention and consent requirements – Collusion and connivance.
19 May 2021
December 2020
22 December 2020
March 2019
18 March 2019
October 1984
12 October 1984
April 1981
Decree nisi granted where admitted adultery and repeated violent assaults constituted cruelty; petitioner did not condone adultery.
Divorce law – Grounds: adultery and cruelty – Jurisdiction over foreign marriage contracted under Southern Rhodesia Marriage Act – Condonation defence considered and rejected.
3 April 1981
October 1980
11 October 1980
July 1980
Decree nisi granted for divorce based on proved cruelty and credible uncorroborated evidence of adultery.
Divorce — cruelty established by physical assaults and continuous fear — adultery proved on uncorroborated but credible testimony — decree nisi granted — costs subject to taxation — custody adjourned.
31 July 1980