Malawi Supreme Court of Appeal - 2018 March

6 judgments

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6 judgments
Citation
Judgment date
March 2018
Court upholds a trial court's power to transfer sittings for security; bail pending appeal denied absent exceptional circumstances.
Criminal procedure – s73(3) transfer of proceedings – court may sit elsewhere for security; Criminal law – bail pending appeal – discretionary, requires unusual/special/exceptional circumstances or interests of justice; duty of full disclosure in affidavits.
29 March 2018
Second‑level appeal dismissed: confession and independent witness evidence upheld; no mandatory duty to read statutory defence at plea.
Criminal law — admissibility and weight of caution statements; Chisenga distinguished — presumption in Theft by Public Servant; hearsay versus direct evidence; statutory defence of reasonable belief on age — no mandatory plea‑stage notice; second‑level appeals limited to questions of law and cannot reopen sentence severity.
29 March 2018
Convictions for theft and money laundering quashed for insufficient proof of lack of legal entitlement and absence of a proven predicate serious offence.
Criminal law – Theft and money laundering – sufficiency of evidence and burden of proof; duplicity and particulars; section 201 witness-calling; money laundering requires proof of a ‘serious’ predicate offence; depositor/banker relationship and title to deposited funds.
23 March 2018
The appellant's unexplained delay and mere inadvertence did not justify condonation to appeal out of time.
Civil procedure – Appeals out of time – Condonation – "Good and substantial reasons" required – Inadvertence or unexplained delay insufficient – Court’s discretion to refuse condonation where delay excessive.
20 March 2018
Interlocutory injunction set aside where damages adequate and balance of convenience favoured realization of security.
Civil procedure – interlocutory injunctions – application of American Cyanamid guidelines; whether serious question to be tried on construction of guarantee; adequacy of damages as remedy; balance of convenience; creditor’s right to realise security unless guarantee expressly requires exhaustion of remedies (Sedam v Mwalubunju).
20 March 2018
Bail pending appeal must be decided by the "interests of justice" test; exceptional circumstances are not an absolute precondition.
Constitutional right to release and bail (s42); Bail pending appeal—governed by interests of justice, not rigid "exceptional circumstances" test; Statutory discretion under s24 Supreme Court of Appeal Act and ss355/359 Criminal Procedure Code; Three-stage enquiry for bail pending appeal (appealable issue; likelihood of success; interests of justice); Caution on reliance on call logs as proof of conspiracy.
14 March 2018