Malawi Supreme Court of Appeal - 2016

25 judgments

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25 judgments
Citation
Judgment date
November 2016
Applicant granted leave to appeal out of time and seven‑day extension due to delayed delivery and non‑notification of judgment.
Civil procedure — Leave to appeal and enlargement of time — Section 23(2) Supreme Court of Appeal Act; Order III r.4 Supreme Court of Appeal Rules — good and substantial reasons for delay and prima facie grounds of appeal required; late or non‑notification of judgment can constitute good cause. Procedural hierarchy — Section 8(b) SCA Act bars importing High Court Rules into SCA procedure. Stay of execution — inappropriate where judgment dismissed the case.
9 November 2016
9 November 2016
October 2016
27 October 2016
A single Justice lacks power to hear appeals or premature interlocutory injunction applications; appeal must be entered and heard by a three‑judge panel.
Appeal procedure – Jurisdiction of single Justice of Supreme Court of Appeal – Section 7 SCA Act – Entry of appeal and record settlement under Order III rules 5–19 (rules 10–11, 19) – Interlocutory injunction pending appeal – Prematurity and abuse of process.
24 October 2016
10 October 2016
September 2016
Applicant must prove special circumstances or inability to repay to secure a stay of execution pending appeal.
Civil procedure — Stay of execution pending appeal — Assessment of interest — Adjournment discretion of Assistant Registrar — Balance of justice and requirement to show special circumstances or inability to repay — Undertaking to repay.
18 September 2016
Stay granted pending appeal where execution risked rendering appeal nugatory and procedural basis for rehearing was upheld.
Civil procedure – Stay of execution pending appeal – Order 59 r.13 Rules of Supreme Court (1999) – applicability in Malawi – rehearing after High Court refusal – not an irregular appeal requiring leave – equitable discretion – unclean hands – intestate estate distribution – risk of rendering appeal nugatory.
6 September 2016
Stay granted where appeal raises substantial issues and execution would render appeal nugatory; Order 59 r.13 held applicable.
Civil procedure — Stay of execution pending appeal — Applicability of Order 59 r.13 (Rules of Supreme Court 1999) in Malawi — Re‑application/rehearing in higher court — Leave to appeal not required — Equitable relief and clean hands — Stay where appeal would be rendered nugatory.
6 September 2016
1 September 2016
August 2016
Delay and failure to prosecute an appeal, not prior counsel’s ineptitude, defeat a stay of execution pending appeal.
Civil procedure — Stay of execution pending appeal — Delay and failure to prosecute — Four-part test (Anglia Book Distributors) — Prior counsel’s negligence not special circumstance — Costs to successful respondent.
31 August 2016
A stay of execution was refused where the applicant failed to show special circumstances or inability to repay and the respondent offered an undertaking.
Civil procedure – Stay of execution pending appeal – balancing right to enjoy fruits of judgment versus preventing appeal being rendered nugatory; appeal not automatic stay. Procedural fairness – refusal to adjourn and right to cross‑examination; matters for appellate review. Interest assessment – specificity of award and undertakings to repay relevant to stay applications.
31 August 2016
11 August 2016
July 2016
26 July 2016
20 July 2016
18 July 2016
11 July 2016
Official bank letters and scanned cheque images may be admissible when tendered by a competent bank officer to show payments despite electronic anomalies.
Evidence — Hearsay — admissibility of official bank correspondence and scanned cheque images; Bankers' Books Evidence Act; competency of bank officer to tender bank records; proof on balance of probabilities where electronic records conflict with other corroborative evidence.
4 July 2016
June 2016
Whether an e-mail and expert report establish a clear admission supporting judgment for an unmerchantable, unfit vehicle.
Judgment on admission — admissibility of confidential third‑party e‑mail — discretion under Order 16 — privacy and improperly obtained evidence — implied conditions: fitness for purpose and merchantable quality — seller/agent liability — expert report on roadworthiness.
22 June 2016
19 June 2016
Failure to file skeletons or delayed record alone did not justify dismissal; appellant must file skeletons 14 days after filing notice of appeal.
Practice Direction No.1 of 2010 – paragraph 1(a)(i): appellant must file skeleton arguments within 14 days of filing the notice of appeal; Supreme Court of Appeal Rules – Order 3 (appeal brought by filing notice of appeal; record filing and registry duties); preparation of record – appellant responsible subject to High Court supervision and registrar duties; dismissal for want of prosecution – principles (inordinate/inexcusable delay, prejudice, contumelious default); delay shared among parties and registry – dismissal refused; timetable and costs ordered.
3 June 2016
May 2016
25 May 2016
April 2016
Employees’ statutory priority on insolvency does not defeat a mortgagee’s proprietary rights over charged property absent winding-up or a subsisting floating charge.
Employment law – s34(3)(d) Employment Act – priority of employee claims on insolvency or winding up – does not trump proprietary rights of mortgagee/chargee over charged property.; Companies Act – debenture/charge – mortgage as debenture; floating charge v fixed charge – crystallisation on demand and appointment of receiver; Registered Land Act s72 – application of sale proceeds of charged property; receivership by chargee distinct from insolvency or winding-up.
25 April 2016
Prolonged failure to pay purchase price repudiated the sale; registration did not defeat seller's lien or bar repudiation.
Contract for sale of land – existence of contract despite staged completion; time for payment not prima facie of the essence; prolonged non-payment as repudiation; vendor’s lien and overriding interests under Registered Land Act preserved; laches and clean hands bar specific performance.
25 April 2016
March 2016
Appeal from a Registrar's assessment of damages lies to the Supreme Court of Appeal under Order 58 RSC; strike-out application dismissed.
Civil procedure — Appeal from assessment of damages by Registrar — Order 58(2)(b) RSC (1999) — Applicability of Rules of the Supreme Court versus Civil Procedure Rules — Interpretation of section 29 Courts Act.
21 March 2016
21 March 2016