Industrial Relations Court of Malawi

57 judgments

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57 judgments
Citation
Judgment date
January 2026
5 January 2026
December 2025
Employer’s failure to consult before retrenchment rendered dismissal unfair; severance and limited salary arrears awarded, other claims dismissed.
Employment law – unfair dismissal for operational requirements – duty to consult employees before retrenchment – entitlement to compensation for unfair dismissal – statutory formula for severance pay – proof required for salary arrears, allowances and pension claims.
12 December 2025
Applicant’s resignation did not amount to constructive dismissal; respondent’s counterclaim of K445,598.00 awarded.
Employment law – Constructive dismissal – Burden on employee to show employer’s conduct unreasonable; failure to follow internal grievance procedures; credibility and evidence required to prove repudiatory breach.
12 December 2025
Assistant Registrar’s inflated assessment varied to statutory minima; pension award and 50% uplift set aside.
Employment law – Assessment of compensation for unfair dismissal – Application of section 63(4) and (5) Employment Act – Use of salary at date of dismissal – Assessing court must not award beyond years of service – Assessing court must respect terms of liability judgment – Employer pension not assessable absent remit – Boosting (uplifting) awards and effect of employee contributory fault.
12 December 2025
November 2025
Non-renewal of fixed-term contracts on expiry is not unfair dismissal where discretionary renewal and project-linked funding apply.
Employment law – fixed-term contracts – termination by effluxion of time – section 28(2) Employment Act – discretionary renewal clause – section 28(3) conversion to unspecified-term contracts – distinction between core and support functions – unfair dismissal and unfair labour practice claims.
28 November 2025
Whether retiring employees are entitled to pension (per Pension Act and Circular B) rather than gratuity.
Pension law – obligation to provide pension under Pension Act – administrative circulars v. statutory law – Circular A (2017) not lawfully displacing statutory pension rights – Circular B (2019) applicable for computing pension-equivalent benefits – entitlement to pension (10% employer contribution applied over employment) rather than gratuity – Industrial Relations Court jurisdiction to determine discrimination-linked labour claims.
28 November 2025
Fixed-term contract expired by effluxion of time; termination not unfair dismissal and all claims dismissed.
Employment law – Fixed-term contracts – Effluxion of time terminates contract – Not unfair dismissal; Employment Act – fixed-term contracts excluded from severance and notice pay; Burden and standard of proof in civil claims – balance of probabilities; Evidential proof of payment – payslips, terminal benefits receipt and pension statements; Discretionary bonuses and statutory pension claims procedure (Pension Act s.62).
28 November 2025
October 2025
Applicants awarded salary-difference and lump-sum damages for unfair labour practices and excessive workload; respondent ordered to produce salary scales.
Employment law – Unfair labour practices – Overloading interns with work of higher grade – Remedy: salary-difference comparator to Staff Associates, lump-sum damages; court-ordered disclosure of comparator salary progression; no notice pay awarded.
2 October 2025
April 2025
Non-renewal of seasonal contracts is not unfair dismissal where seasonal employment ended and terminal benefits were paid.
Employment law – Seasonal employment – Section 43 (continuous seasons) – Unfair dismissal burden under s61 – Non-renewal of seasonal contracts not unfair dismissal where contracts end and terminal benefits paid.
11 April 2025
Court stayed disciplinary processes and dismissal pending trial given triable issues over tribunal competence and executive authority.
Industrial Relations Court — Interim relief — Stay of disciplinary proceedings pending trial; Unfair dismissal — Competence of disciplinary tribunal in absence of sitting board; Authority of corporate officers vis-à-vis MEMARTS; Risk of prejudice and reinstatement remedy.
1 April 2025
November 2024
Employer breached its redundancy policy and failed to meaningfully consult, rendering the dismissal unfair and attracting compensation.
Employment law – redundancy and retrenchment – s.57(1) Employment Act – duty to consult where employer’s terms/policy require it – relevance of ILO Termination of Employment Convention No.158 and Ministry of Labour guidelines – procedural fairness, meaningful consultation and use of proper evidence – unfair dismissal and compensation.
1 November 2024
June 2024
Employee unfairly dismissed due to procedural bias and defective charges; awarded compensation, severance and notice pay.
Employment law – Unfair dismissal – Procedural fairness and natural justice – Investigator sitting on disciplinary panel (bias) – Insufficient particulars in charges – Employer’s burden to prove valid reason and act with justice and equity – Compensation and severance calculations – Bonus eligibility.
24 June 2024
May 2024
Dismissal for negligently authorising suspect cheques and poor supervision was substantively and procedurally fair.
Employment law - unfair dismissal; supervisory duty and record-keeping in banking; negligence/recklessness in authorising cheques; procedural fairness in disciplinary hearings; discrimination and proportionality of dismissal.
3 May 2024
March 2024
Assessment of compensation for unfair dismissal: five months’ pay per year, pension, and 200% boost for inflationary devaluation.
Employment law – Unfair dismissal for non‑hearing (s57, s58 Employment Act) – Compensation assessment (s63(4) & s63(5)) – Years of service post‑privatisation – Employer pension contributions – Boosting awards for devaluation/inflation.
26 March 2024
February 2024
Court dismissed motion to restore stay where respondent failed to prosecute appeal and counsel cited no law, awarding costs to applicants.
Civil procedure — stay of execution pending appeal — prolonged failure to prosecute appeal — court's power to set aside irregular steps (Rule 25(k)) — requirement to cite governing law in motions.
27 February 2024
Court awarded one month’s pay per year, doubled for devaluation, and rejected unproven bonus claims.
Employment law – Unfair dismissal – Assessment of compensation under s63(4) and (5) Employment Act – One month’s pay per completed year awarded – Claim for 2018 bonuses failed for lack of evidence – 100% uplift granted for currency devaluation and inflation.
20 February 2024
Applicant proved entitlement to withheld wages, leave, overtime and pension; court awarded principal plus interest totalling MK801,738.71.
Employment law – withholding of wages and terminal benefits – entitlement to unpaid leave, overtime, wages and pension contributions; burden of proof on balance of probabilities where respondent absent; interest awardable on wrongfully withheld terminal dues (s.53 Employment (Amendment) Act 2010).
20 February 2024
Assessment of unfair dismissal compensation using current salary to preserve purchasing power; partial contribution reduces award; severance computed accordingly.
Unfair dismissal — procedural fairness — denial of right to confront witnesses; Compensation under s.63(4)–(5) Employment Act; Use of current salary to preserve purchasing power; Partial employee contribution reduces award; Severance computation under First Schedule and s.35(2); Appeal does not stay award — 50% payment pending appeal.
20 February 2024
January 2024
Employer must consult employees before retrenchment; ministerial forced leave without consultation amounted to unfair dismissal and unfair labour practices.
Labour law — retrenchment — duty to consult employees before operational dismissals — Ministerial directive without Board authority — unfair dismissal; unfair and unsafe labour practices — compensation assessment.
29 January 2024
Respondent’s internal negligence or poor communication does not justify setting aside a default judgment or staying its execution.
Industrial Relations Court – default judgment – service of process – setting aside default judgment – stay of execution pending appeal – burden to show special circumstances – internal negligence not sufficient – assessment of compensation to proceed.
17 January 2024
Stay of execution pending appeal denied for lack of special circumstances and misleading conduct; costs awarded; enforcement ordered.
Civil procedure — Stay of execution pending appeal — applicant must show special circumstances; duly served party’s non-attendance and misleading affidavits negate entitlement to stay; costs may be awarded where motion is frivolous or dilatory.
2 January 2024
December 2023
Dismissal for mis‑posting and failure to account held substantively and procedurally fair; dismissal not unfair.
Employment law – Unfair dismissal – substantive fairness: mis‑posting and failure to account for customer deposits; banks’ statutory duty; procedural fairness – notice and representation; burden shift under s61 Employment Act; s57 valid reason for dismissal.
24 December 2023
September 2023
Dismissal unfair where employer failed to prove misconduct and denied procedural fairness.
Employment law – unfair dismissal – substantive fairness (insufficient and ambiguous evidence of misconduct) – procedural fairness (failure to disclose evidence, lack of particularity of charges, inability to cross-examine accuser, potential bias of panellist) – burden on employer under s.61 Employment Act.
25 September 2023
August 2023
Statutory compensation under s.63, not common‑law damages, governs unfair dismissal awards; upward departures require clear, justifiable reasons.
Employment Act s.63 — statutory compensation for unfair dismissal; distinction from common‑law damages; s.63(5) minima based on remuneration and years of service up to dismissal; s.63(4) just and equitable uplift—must be justified; improper use of immediate/future loss heads; review powers under r.5A(2).
17 August 2023
July 2023
Applicants unfairly dismissed without a hearing; court awarded full remaining-contract compensation and severance under section 63(4).
Employment law – unfair dismissal – procedural fairness (audi alteram partem) – section 57 (grounds for termination) – section 63(4) and (5) (compensation framework) – discretion to depart from statutory minima – severance for prior service.
24 July 2023
February 2023
Application to set aside interim half-pay order dismissed; delay and non-service not fatal; interim relief not substantive.
Industrial relations — Interim relief under IRC Rule 25(1)(m) — setting aside interlocutory orders — delay and non-service — distinction between interlocutory relief and substantive relief.
22 February 2023
October 2022
Assessment of pension and accrued leave after default judgment; uncontroverted evidence and statutory rules determine compensation.
Industrial Relations Court – assessment of compensation after default judgment – uncontroverted evidence due to respondent's non‑attendance – pension contributions (Pensions Act 2011, 10% employer minimum) – accrued leave pay – just and equitable compensation (Employment Act s63) – currency devaluation adjustment – costs awarded.
18 October 2022
February 2022
Court awarded limited compensation for personal loss of vehicle use, rejecting unpleaded pension and salary claims.
Employment law — unfair labour practice — assessment of compensation — importance of pleadings — unpleaded claims excluded — quantification of loss of use of official vehicle.
24 February 2022
March 2021
The court found both dismissals unfair for lack of substantiated reasons and inadequate investigation, awarding compensation.
Employment law – unfair dismissal – burden on employer under section 61(1) – substantive and procedural fairness – Burchell/Polkey investigative standards – summary dismissal and reasonable suspicion.
10 March 2021
November 2020
Dismissal unfair: employer failed to prove misconduct and denied the employee a meaningful opportunity to call witnesses; compensation ordered.
Employment law – unfair dismissal – burden of proof on employer – right to a meaningful hearing and to call witnesses – insufficient evidence linking employee to alleged theft – compensation assessment by Registrar.
16 November 2020
October 2020
Dismissal for alleged loss of equipment was unfair because employer failed to consider mitigating factors; compensation ordered to be assessed.
Employment law – unfair dismissal – employer’s burden to prove substantive and procedural fairness – consideration of mitigating factors (length of service, past record, recovery of property) – compensation under s.63 Employment Act.
23 October 2020
July 2020
Review court affirmed five‑month damages for unfair dismissal, rejected 24‑month claim, and added five months’ allowances.
Employment law – unfair dismissal – compensation under s.63 Employment Act – measure of damages is prima facie earnings subject to mitigation – fixed‑term contracts – employment not for life – inclusion of allowances/fringe benefits in compensation – review of Registrar’s assessment under Rule 5A(2).
31 July 2020
The applicant failed to discharge the burden of proof for terminal benefits; Labour Office calculations alone were inadequate.
Employment law – terminal benefits – burden of proof on employee to prove leave pay, gratuity, notice pay and service allowance; Labour Office calculation sheets insufficient without evidential foundation; signed acknowledgements of payments relevant to claim.
29 July 2020
Short notice, added charge and denied cross-examination rendered the dismissal procedurally unfair; damages and severance ordered.
Employment law — unfair dismissal; natural justice and procedural fairness — adequate notice to prepare, particularisation of charges, right to cross-examine adverse witnesses; unproven allegations cannot ground summary dismissal; damages and severance to be assessed.
28 July 2020
May 2020
Employer may deduct for shortages but must give prior written notice and an opportunity to be heard before deducting terminal benefits.
Employment law – Deductions for shortages – Restitution from terminal benefits; Procedural fairness – Right to be heard and written reasons – Constitution ss. 43 & 31; Lawful entitlement to deduct does not excuse failure to follow natural justice; Pension protection from deduction (limited).
22 May 2020
Employee unfairly dismissed due to procedural defects and apparent bias; awarded compensation, other claims dismissed.
Employment law – unfair dismissal – section 57 Employment Act – procedural fairness (notice, particulars, reasonable time, right to call and cross‑examine witnesses) – apprehended bias of decision‑maker – remedies: compensation, notice pay, severance, pension contributions.
19 May 2020
April 2020
Claim for unfair dismissal dismissed where contract was frustrated by employee's mental incapacity and resignation precluded notice pay.
Employment law — Unfair dismissal — Frustration of contract by employee incapacity (mental illness) — Resignation following disciplinary process — Entitlement to notice pay.
30 April 2020
January 2020
Employer failed to substantiate gross-negligence dismissal; termination unfair and compensation ordered, repatriation costs reserved for assessment.
Labour law – unfair dismissal; employer’s evidential burden under s.61(1) Employment Act; justice and equity requirement under s.61(2); supervisor liability for subordinate actions; disciplinary procedure and procedural fairness; repatriation costs reserved for assessment.
20 January 2020
December 2019
Substantive reason for dismissal proven but procedural breaches (no written charges, no proper appeal) rendered the dismissal unfair, entitling remedies.
Employment law — unfair dismissal — substantive validity of reason (negligence) established but procedural fairness breached — failure to give written charges and hold proper appeal — compensation and severance payable.
10 December 2019
Summary dismissal for gross negligence (sleeping on duty) upheld where employer afforded hearing and relied on prior warnings.
Employment law – Summary dismissal – Gross negligence (sleeping on duty) – Burden on employer to prove reason on balance of probabilities – Right to be heard – Prior warnings relevant to fairness – Sections 57, 59, 61 Employment Act.
4 December 2019
November 2019
Dismissal was procedurally and substantively unfair; inadequate notice, biased appeal, employer failed to prove a valid reason.
Employment law – unfair dismissal – procedural fairness (adequate notice, particulars, right to be heard) – natural justice and bias in internal appeals – employer's onus to prove valid reason – remedies: compensation and severance.
18 November 2019
Employer failed to prove alleged fuel siphoning or conduct a reasonable investigation; dismissal held unfair and damages plus statutory terminal benefits ordered.
Employment law – unfair dismissal – employer bears burden to prove dismissal fair – reliance on vehicle tracking reports insufficient without adequate investigation or physical evidence – entitlement to damages and statutory terminal benefits.
6 November 2019
October 2019
Applicant’s dismissal for alleged fuel theft held lawful; claims for unfair dismissal and terminal benefits dismissed.
Employment law – unfair dismissal – Employment Act ss.57, 58, 61 – employer’s burden to justify dismissal – anonymous tip-off and fuel-consumption evidence – disciplinary hearing and right to be heard – payment of terminal benefits evidenced.
29 October 2019
September 2019
Dismissals held unfair due to multiple procedural breaches in the employer's disciplinary and appeal processes.
Employment law – unfair dismissal – disciplinary procedure – investigator participating on disciplinary panel – insufficient particulars in charges – improperly constituted disciplinary and appeal committees – procedural fairness required under Employment Act and employer's Disciplinary Policy.
20 September 2019
August 2019
Dismissal procedurally unfair for lack of hearing; applicant awarded six months' pay, no additional terminal benefits.
Labour law — disciplinary versus criminal proceedings — acquittal not necessarily dispositive in workplace discipline; procedural fairness — right to be heard before dismissal; remedies — reduced/nominal compensation where employee contributed to dismissal; terminal benefits — receipts as evidence of payment.
23 August 2019
Employer failed to prove valid reason or fair procedure; dismissal declared unfair and respondent ordered to pay compensation and terminal dues.
Employment law – unfair dismissal – burden on employer to prove valid reason and procedural fairness – contradictions in disciplinary record and caution statement – entitlement to compensation and terminal benefits.
15 August 2019
A casual labourer released during a slack period was not unfairly dismissed; respondent must pay six days' wages if unpaid.
Employment law – casual worker v. permanent employee – definition of casual work – unfair dismissal – recall after slack period – entitlement to wages for days worked
13 August 2019
July 2019
Fixed-term security guards failed to prove entitlement to severance, separate housing allowance, salary arrears or holiday overtime.
Employment law – severance pay – fixed-term contracts – s35(7) Employment Act; housing allowance incorporated into salary by government directive; minimum-wage adjustments and salary arrears; public-holiday work compensated by substitute leave; burden of proof on claimant.
17 July 2019
An acquittal in criminal proceedings does not automatically make a dismissal unfair; employers may proceed with disciplinary hearings concurrently.
Labour law – Disciplinary versus criminal proceedings – Parallel and concurrent processes permissible; Acquittal in criminal court not determinative of disciplinary outcome; Natural justice – right to be heard and waiver by non-attendance.
2 July 2019
June 2019
Non-renewal of fixed-term contracts by effluxion of time does not entitle employees to severance allowance.
Employment law – Fixed-term contracts – Termination by effluxion of time; Non-renewal not dismissal; Severance allowance under section 35 limited to redundancy/retrenchment; Interaction with Pension Act on accrued severance liabilities; Claim for withheld wages where non-renewal notified.
27 June 2019