Malawi Supreme Court of Appeal - 2017

27 judgments
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Results. 27 judgments found.

27 judgments
December 2017
Application to stay assessment of damages pending appeal dismissed as premature and lacking evidence of irreparable prejudice.
  • Civil procedure — Stay of proceedings pending appeal — interlocutory judgment where damages to be assessed — discretion to grant stay guided by risk of injustice — applicant must show inability to recover payments or special circumstances — prematurity of application to stay assessment; appropriate remedy is stay of execution after assessment.
20 December 2017
Applicant’s direct application for interim injunction refused; must apply to court below first and consent order barred variation without fresh action.
  • Civil procedure — interim injunction pending appeal — requirement to apply first in the court below (Order I r 18) — leave to appeal — consent order as binding agreement not varied by summons — mortgage law — power of sale and balance of convenience.
20 December 2017
Court dismissed interim injunction to restrain bank sale due to procedural defects and weak substantive grounds.
  • Civil procedure — Interim injunction pending appeal — Requirement to apply first in the court below (Order I r 18) — Leave to appeal required (proviso to s.21) — Consent order binding; variation requires fresh action — Mortgage law: reluctance to restrain power of sale where mortgagor defaults.
20 December 2017
An unconditionally admitted counsel has a right of audience that can only be removed by statutory procedure; Oberem v Oberem stands until set aside.
  • Right of audience on admission to the bar; removal of right of audience only by statutory process; requirement for gazetting subsidiary legislation; Malawi Law Society standards; High Court/Chief Justice procedure to remove counsel’s standing; effect of Oberem v Oberem pending appeal.
7 December 2017
November 2017
Court refused to adopt a 14‑day initial skeleton‑argument rule and ordered the record of appeal prepared by 15 December 2017.
  • Civil procedure — case management — service and timing of skeleton arguments — whether appellants must file initial skeleton arguments within 14 days — precedential value of Anglia Book Distributors decision — adoption of domestic Practice Directions versus importation of English CPR practice — preparation of record of appeal.
1 November 2017
October 2017
Court allowed amendment and late filing of skeleton arguments subject to costs payable within 60 days or before the hearing.
  • Civil procedure — Appeals — Application to amend grounds of appeal — Application to file skeleton arguments out of time — Court’s discretion to allow lateness where delay is reasonably explained and any prejudice can be compensated by costs — Costs ordered payable within specified period, non-payment to attract procedural consequences.
26 October 2017
September 2017
Appeals from a registrar’s assessment of damages/interest lie to the Supreme Court of Appeal, not to a judge in chambers.
  • Courts Act s29 (repeal) — General Interpretation Act s13 (continuation of repealed law) — jurisdiction of Supreme Court of Appeal — Registrar’s assessment of damages/interest — Rule 3 High Court (Exercise of Jurisdiction of Registrar) Rules — Order 58(2)(b) Rules of Supreme Court — appeals lie to Supreme Court of Appeal, not judge in chambers.
21 September 2017
Appeal from a Senior Deputy Registrar in wrong forum, late filing and irregular affidavit; court awards costs to applicant/respondent.
  • Civil procedure — Appellate jurisdiction — Appeal from Senior Deputy Registrar must lie to Judge in Chambers — Wrong forum and late filing — Defective affidavit not to be regularised by appellate court — Costs for procedural applications.
20 September 2017
Stay granted of assessment proceedings pending appeal due to procedural irregularities and risk of injustice to the appellant.
  • Civil procedure — Stay of proceedings pending appeal — Discretionary exercise governed by risk of injustice and prejudice — Interlocutory judgment entered at scheduling conference — Procedural irregularities and assessment of damages by Registrar.
20 September 2017
Stay of execution refused where applicant misled court about a pending appeal and sought a stay contingent on a future appeal.
  • Civil procedure — Stay of execution — Continuation of ex parte interim stay — Leave to appeal not yet sought — Suppression of material facts — Stay contingent on future appeal untenable — Matters of merit to be determined by lower court.
19 September 2017
Court set aside ex parte stay of possession but kept title deeds in custody and barred disposition of property pending appeal, with no costs order due to legal aid.
  • Civil procedure — stay of execution — continuation or vacation of ex parte stay — setting aside ex parte stay on inter partes application; interim protection of title deeds pending appeal; prohibition on sale, pledge or mortgage of disputed property without appellate court permission; costs and legal aid.
13 September 2017
5 September 2017
August 2017
Whether the applicant proved a real possibility of judicial bias from prior comments and decisions, warranting recusal.
  • Judicial independence — Recusal/Apprehended bias — Whether extrajudicial/intra‑judicial comments or prior judicial views create a real possibility of bias — Fair‑minded and informed observer test — Code of Conduct/Constitution
  • Criminal procedure — Bail pending appeal — Test for grant of bail after conviction — Interests of justice versus exceptional circumstances — Section 24(1) Supreme Court of Appeal Act; s355 Criminal Procedure and Evidence Code
  • Bias — Timing and context — Effect of passage of time and intervening binding decisions on recusal applications
12 August 2017
July 2017
Leave to judicially review anti-corruption investigations denied; prosecutorial discretion and investigatory process upheld.
  • Administrative law — Judicial review — Leave to apply — Prosecutorial discretion and investigatory powers under the Corrupt Practices Act — Delay and timeliness (Order 53 r.4) — Reasonableness and bad faith — Premature challenge to prosecution decision.
19 July 2017
June 2017
Appeals from a registrar’s assessment of damages lie to the Supreme Court of Appeal; appeals to a judge in chambers are a nullity.
  • Appeals — appellate jurisdiction governed by Supreme Court of Appeal Act — Registrars’ assessments of damages are judgments appealable to the Supreme Court of Appeal — Rule 3 of the High Court (Exercise of Jurisdiction of the Registrar) Rules does not displace Order 58, rule 2(1)(b) — appeal to judge in chambers on assessment was nullity — Civil Procedure Rules 1998 and Practice Directions relevant to permission and procedure.
20 June 2017
April 2017
Supreme Court dismissed stay application as an abuse of process amid overlapping interlocutory proceedings and ordered each party to bear own costs.
  • Civil procedure — Stay of execution pending appeal — Abuse of court process where multiple overlapping interlocutory applications pursued — Applicants must elect appropriate procedural route — Costs: each party to bear own.
24 April 2017
Applicant must exhaust tax-law remedies; no stay granted where Commissioner General had already determined the appeal.
  • Tax procedure — stay of execution — whether stay appropriate where Commissioner General has determined appeal within statutory period; requirement to exhaust statutory tax remedies; Court’s inability to stay proceedings before Commissioner General; adjournment and substitution of counsel.
24 April 2017
11 April 2017
A stay cannot be granted where there is no execution because the judgment has been paid into court pending appeal.
  • Civil procedure — Stay of execution — Where judgment ordered paid into court pending appeal there is no execution to stay; application for stay of 'phantom execution' is misconceived — Leave to appeal not required merely because judgment delivered in chambers.
11 April 2017
March 2017
Interlocutory injunction refused where statutory employment dismissal raised private law issues and damages were adequate.
  • Interlocutory injunctions — American Cyanamid principles — employment versus judicial review (Order 53) — statutory postholder dismissal — doctrine of necessity on bias — adequacy of damages; Electoral Commission Act s.12.
6 March 2017
Destruction and non-preservation of electoral materials by the Electoral Commission justified a re-run; appellant’s election invalidated.
  • Electoral law — preservation of electoral materials — s119 PPEA; Election petitions — standard of proof — satisfaction of the court; Destruction of ballot boxes — adverse inference where custodian fails to preserve evidence; Recount frustrated — re-run as appropriate remedy; Notification of interested candidates and procedural fairness.
6 March 2017
February 2017
An ex parte interim injunction against a minister, granted without a proper application or evidence, was vacated; judicial review procedure must follow CPR 1998.
  • Civil procedure — Judicial review procedure (Part 54 CPR 1998) — Interim remedies (Part 25) — Ex parte interlocutory injunctions — Vacatur where no specific application or evidence — Grant of leave does not automatically result in injunction or stay — Commissions of inquiry — resignation/suspension of public officers — interpretation of "Rules of the Supreme Court 1999" as CPR 1998 (26 April 1999).
8 February 2017
The appellant's purchase and possession of customary land created an equitable proprietary interest defeating the first respondent's later lease.
  • [Customary land] Nature of customary land title; sui generis proprietary interest; vesting in President does not negate intermediary proprietary rights; sale/alienation of customary land subject to customary law; equitable interest arising on contract and part performance/possession; purchaser in possession gives notice; appellate rehearing powers; trespass and damages for unlawful construction.
8 February 2017
Where joint ownership was intended but contributions are indeterminate, courts may award each party a 50% beneficial interest.
  • Family law — division of matrimonial property; matrimonial/home converted properties — equality is equity where contributions indeterminate; contribution to development as basis for beneficial interest; household expenditures insufficiently particularised to establish proprietary claim; custody does not automatically entitle provision of a home; child maintenance and school fees — shared responsibility
2 February 2017
January 2017
Delay, non‑prosecution and procedural defects justify refusal of stay and refusal to certify a defective constitutional referral.
  • Civil procedure — stay of execution — default judgment — laches and non‑prosecution; Criminal procedure — section 302A CPEC — applicability where accused not charged; Constitutional procedure — referral/certification under Rule 8 and Chief Justice’s role — originating motion required for non‑referral constitutional challenges; Court’s duty to assess substantiality before referral; Registry and drafting obligations.
24 January 2017
Expired statutory custody limits make detention unlawful; bail decisions must follow custody rules and Bail Guidelines.
  • Constitutional right to release — s.42(2)(e); Custody time limits — ss.161A–161J CPEC mandatory; No power to extend time after expiry except as statutorily provided; Bail incidental to release; Bail Guidelines Act — mandatory factors and information duty; Juvenile protections; Remittal for reconsideration.
11 January 2017
Failure to apply mandatory Bail Guidelines and exceeded custody time limits justified bail pending appeal.
  • Criminal procedure — bail — distinction between constitutional right to release (s.42(2)(e)) and statutory bail (s.118) — applicant must prove threshold facts; State bears evidential burden. Bail (Guidelines) Act and Guidelines mandatory — courts must consider all prescribed factors and may order production of missing information. Custody time limits (s.161A–161J) binding — detention beyond limits requires release. Bail pending appeal — application should accompany notice of appeal but Court may waive and hear it. Single member cannot determine substantive bail appeal; full court required
9 January 2017