High Court of Malawi Revenue Division

23 judgments

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23 judgments
Citation
Judgment date
March 2025
30 March 2025
March 2023
Succeeding magistrate must expressly find delay or expense unreasonable before refusing accused's request to recall witnesses under section 165.
Criminal procedure — Change of magistrate — Section 165 Criminal Procedure and Evidence Code — Duty to re-summon witnesses on accused's request unless magistrate finds delay or expense would be unreasonable — requirement to form and record express opinion — remittal for reconsideration.
24 March 2023
February 2023
Court dismissed appeal, upholding lower court’s extension of time and holding Taxation Act (8th Schedule) governs appeals from Special Arbitrator.
Taxation Act (8th Schedule) – appeals from Special Arbitrator to High Court – 21-day notice and 42-day grounds time limits; jurisdiction to grant extension of time; discretion to extend time; functus officio and res judicata inapplicable to procedural extension applications; Subordinate Court Rules not applicable.
15 February 2023
Court dismissed challenge to prosecution for alleged VAT fraud, finding no abuse of process and stayed related civil proceedings pending criminal trial.
Judicial review — Prosecutorial discretion — Abuse of process — Concurrent civil and criminal proceedings — Tax prosecutions — Section 155 Customs and Excise Act (five‑year limitation) — Reasonable and probable cause; evidential and public‑interest test.
15 February 2023
July 2022
Where no statutory appeal exists from a special referee, judicial review is the appropriate remedy.
Customs and Excise Act s121 - Special Referee determinations - no implied appeal where statute silent - judicial review is the correct remedy - strict interpretation of tax statutes - refusal to convert appeal into judicial review; costs awarded.
28 July 2022
Cancellation of an industrial rebate without a hearing breached the constitutional right to fair administrative action.
Administrative law — Right to lawful and procedurally fair administrative action (s43 Constitution) — Legitimate expectation to be heard before withdrawal of benefits — Customs and Excise Regulations (Reg 116, Para 13) — Investigations do not substitute for administrative hearing — Certiorari to quash unlawful cancellation.
28 July 2022
June 2022
An application to amend a Notice of Appeal to add particulars of alleged misdirection was dismissed for violating conciseness rules.
Civil procedure – Amendment of Notice of Appeal – Order 111 rule 2(2) and rule 2(3) – Particulars of alleged misdirection or error in law – Requirement that grounds of appeal be concise and non‑argumentative – Discretion to refuse amendment.
15 June 2022
Whether refusing the applicant a duty-free disposal of a vehicle violated constitutional protection of judicial benefits and equality.
Constitutional law – protection of judicial remuneration and benefits (s114) – administrative law – legitimate expectation and Wednesbury unreasonableness – statutory interpretation (expressio unius; absurdity canon) – tax law – limits on levying revenue (s171) – Customs and Excise Act s121(1) jurisdictional scope.
7 June 2022
May 2022
Claimant’s failure to exhaust available remedies bars judicial review of a tax demand lacking a separate pre-action hearing.
Tax law – pay-now-argue-later (section 105 Taxation Act) – pre-action hearing and administrative fairness (section 43 Constitution) – exhaustion of alternative remedies – permission for judicial review.
6 May 2022
October 2021
Whether the Commissioner General is a necessary party to judicial review of his refusal to allow duty‑free vehicle disposal.
Judicial review – decision by Commissioner General of revenue authority refusing duty‑free disposal of vehicle – whether Commissioner is proper and necessary party – Order 6 r.8 (CPR) – Order 20 r.1(b)(iii) (judicial review jurisdiction) – interpretation and application of Customs Procedure Code.
7 October 2021
Payment of an importer's fine does not entitle the claimant to release of a seized vehicle.
Customs law — seizure of conveyances — conveying smuggled goods — separate offences for importer and transporter — s.137(2) reasonable precautions defence — s.145/s.146 seizure and forfeiture powers.
7 October 2021
July 2021
20 July 2021
October 2020
27 October 2020
February 2020
20 February 2020
December 2019
19 December 2019
November 2019
29 November 2019
October 2019
10 October 2019
March 2019
13 March 2019
Historical acquiescence to withholding tax credits created a legitimate expectation; enforcement without objective assessment was arbitrary and quashed.
Tax law — administrative justice — legitimate expectation from longstanding acquiescence to withholding tax credit settlements; equality in tax administration; procedural fairness and reasons; Wednesbury unreasonableness of enforcement without objective assessment of alternatives; quashing and mandatory relief.
11 March 2019
September 2018
Applicant granted leave to appeal but stay pending appeal denied due to lack of evidence and absence of cause of action.
Civil procedure — Leave to appeal — Stay pending appeal — Balancing successful litigant’s right to enforcement against appellant’s right of appeal — Requirement of evidence that enforcement would render restitution impossible — Absence of cause of action as factor against stay.
13 September 2018
May 2018
Court refused to halt vehicle investigations absent evidence of malice or illegality, vacated interim stay and awarded damages.
Judicial review — Investigative and prosecutorial discretion — Search warrants and customs investigations — Reasonable suspicion required — No interference absent illegality, mala fides or exceptional circumstances — Interim stay vacated; damages for wrongful interim order.
22 May 2018
November 2017
6 November 2017
September 2017
18 September 2017