National Traditional Appeal Court

17 judgments

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17 judgments
Citation
Judgment date
July 2022
Appeal dismissed but cross-appeal allowed: hearsay evidence rejected, MK200,000,000 damages set aside for lack of evidential basis.
Civil procedure – appeal from assessment under consent order – refusal to admit new evidence on appeal; Evidence – hearsay rule and exceptions – witness non-authority of documents; Damages – requirement to strictly prove special damages under a consent order; Interest on damages – availability limited to debts or judgment debts under statutory provisions.
12 July 2022
May 1983
Under customary law, lack of support is usually compensatory and insufficient alone to dissolve a marriage without strong evidence.
Customary marriage — preservation and reconciliation — high threshold for dissolution; failure to support generally compensatory, not grounds for divorce absent compelling evidence.
26 May 1983
August 1981
Under customary law, unsupported allegations of neglect and contradictory evidence do not justify dissolving a marriage; compensation may be ordered instead.
Customary marriage – dissolution – high threshold for divorce – requirement to allow advocates to reconcile parties – misconduct often remedied by compensation not dissolution – credibility of evidence on appeal.
26 August 1981
Wife entitled to reclaim wedding chattels; lobola does not vest ownership in husband; appeal dismissed.
Customary law — matrimonial property — entitlement of wife to items she brought into marriage; Lobola — does not transfer ownership of bride's wedding gifts; Traditional Courts Act — Commissioner’s power to direct hearing despite territorial jurisdiction defects; Appeal procedure — ex parte hearing where respondent absent.
26 August 1981
May 1981
Appellant's challenges failed: a subsisting customary marriage was found, respondent may use husband's name, appeal dismissed with costs.
Customary marriage — validity — presumption attached to registered marriage certificate; use of husband's surname during subsistence of marriage; nkhoswe (advocates) requirements at customary law; duress — burden to rebut; jurisdiction to dissolve customary marriage.
4 May 1981
August 1980
Appeal dismissed where evidence established respondent's claim for chisuzula after the applicant's desertion and paternity was proven.
Customary law – abandonment of marriage (Kundisiya Ukwati popanda chifukwa) – chisuzula – proof of paternity – appeal dismissed for lack of merit.
21 August 1980
Cohabitation was not a proven marriage and respondent failed to prove theft of property; appeal allowed with costs.
Traditional/customary union — cohabitation not established as marriage; property dispute — burden of proof; balance of probabilities; failure to call corroborative witnesses; costs awarded.
18 August 1980
January 1980
Divorce granted for wilful non-consummation; customary law awards custody and lobola to the innocent spouse, and costs to the petitioner.
Family law – Divorce for wilful refusal to consummate marriage; customary law consequences – forfeiture of lobola and custody awarded to the innocent spouse.
19 January 1980
November 1979
Where lobola is required by customary law, cohabitation without lobola does not create a valid marriage.
Customary law – lobola (bridewealth) as prerequisite to marriage – cohabitation without lobola not a valid marriage – betrothal compensation.
1 November 1979
October 1979
Cohabitation without Chinkhoswe does not create enforceable marital rights; detinue claim dismissed as domestic matter.
Detinue; customary marriage (Chinkhoswe) — cohabitation without customary rites — no enforceable marital rights; domestic disputes adjudicable by ankhoswe; alleged assault and police inaction relevant to credibility and relief.
22 October 1979
August 1979
Under Mzimba customary law, cruelty and constructive desertion by an intended inheritor justify divorce and entitlement to dowry and custody.
Customary marriage — widow (chokolo) rights; inheritance/ levirate; cruelty and constructive desertion as grounds for divorce; entitlement to dowry and child custody where chosen inheritor refuses.
15 August 1979
Repeated elopement of a married woman creates separate compensatory liability for each occasion; appeal allowed.
Customary law — elopement of married woman — repeated elopement attracts separate compensatory liability; distinction for unmarried woman; judgment in absentia under Traditional Courts Procedure Rules r.38.
9 August 1979
June 1979
No customary marriage without chinkhoswe; maintenance order clarified to K12 monthly for six years.
Customary law – validity of marriage – chinkhoswe as essential to customary marriage; concubinage versus marriage; maintenance orders – uncertainty and substitution; compensation claims in absence of customary marriage.
15 June 1979
May 1979
A customary marriage requires chinkhoswe; absent it, cohabitation carries no enforceable marital rights and compensation was wrongly awarded.
Customary marriage — chinkhoswe (ankhoswe) essential for legal recognition — cohabitation alone insufficient; no compensation for desertion absent valid customary marriage; refund of payments made under erroneous orders; welfare-based maintenance may be available for children of unrecognised unions.
29 May 1979
April 1977
Traditional Court quashes divorce where reconciliation was not attempted, grounds were unproven, and customary link between dowry and custody was ignored.
Traditional Courts — Divorce practice — parties ordinarily sent home to reconcile before dissolution; insufficient evidence — allegations of secret medicine visit and unexplained injury rejected; customary rule — dowry and custody linked and should not be split; quashing of wrongful divorce decree.
21 April 1977
Appeal allowed; maintenance order found satisfied and determined; child remains the appellant's responsibility.
Customary law — dissolution of marriage for desertion — ritual observance and customary 'fisi' practice — maintenance payments — overpayment determines order.
21 April 1977
January 1974
A widow who refuses levirate succession under customary law may obtain a divorce and is free to remarry.
Customary law – widow’s rights on husband’s death – choice between levirate succession and freedom to remarry – refusal to enter succession permits divorce.
23 January 1974