Malawi Supreme Court of Appeal - 2018

17 judgments

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17 judgments
Citation
Judgment date
November 2018
An appeal is premature where liability is decided but damages remain unassessed; only final judgments are ordinarily appealable.
Civil procedure — Appeals — Finality — Appeal premature where lower court has decided liability but damages remain unassessed; inchoate/non‑enforceable judgments not ordinarily appealable; costs in the cause.
29 November 2018
An appeal on liability is premature if damages remain unquantified and the judgment below is inchoate; appeal delisted.
Civil procedure — Appeal — Premature appeal where damages remain unquantified — Inchoate judgment not immediately enforceable — Appeals should follow final determination of liability and quantum — Appeal delisted; costs in the cause.
29 November 2018
Summary judgment improperly entered amid disputed negligence and valuation; appeal allowed and matter remitted to Commercial Division for full hearing.
Civil procedure – Summary judgment – Improper entry and confirmation where negligence and valuation were disputed; Commercial jurisdiction – matter remitted to High Court Commercial Division for full and expedited hearing.
28 November 2018
A s40 Commission order recorded as a High Court judgment must be challenged by appeal to a Judge in Chambers, not by judicial review.
Competition and Fair Trading Act s40(2) – lodgement with Registrar – recorded order has effect of High Court judgment; s48 – appeal to a Judge in Chambers is the proper remedy against Commission findings; judicial review not available against orders recorded as High Court judgments; High Court cannot judicially review its own decisions or those of a court of concurrent jurisdiction; procedural compliance — filing address for service and consequence of non-compliance (ex parte hearing).
26 November 2018
An appeal on liability alone is premature where damages remain unquantified; appeals should await a final, enforceable judgment.
Civil procedure — Appeals — Prematurity of appeal where damages remain unquantified — Judgment left inchoate and not immediately enforceable — Avoidance of piecemeal appeals on liability and quantum.
23 November 2018
September 2018
A single-member may grant an interlocutory stay pending appeal but cannot strike out a notice of appeal; stay granted to protect tracing of funds.
Civil procedure – interlocutory powers of a single member of Supreme Court – limits on use of inherent jurisdiction – power to stay execution pending appeal; locus standi in public interest litigation; freezing orders and risk of dissipation of assets.
14 September 2018
May 2018
Court ordered interim bail after finding nearly two-year unlawful pre-trial detention and State neglect of timely trial obligations.
Constitutional right to personal liberty – pre-trial detention limits – Criminal Procedure and Evidence Code ss.161G–161I – State’s duty to commence trial within reasonable time – unlawful prolonged detention – juvenile treatment – bail pending trial.
30 May 2018
The court refused to stay enforcement pending appeal, finding no irreparable harm or irregular enforcement.
Civil procedure — Stay of execution pending appeal — Requirements for stay: special circumstances, irreparable harm, balance of convenience — Enforcement of possession orders — Sheriff’s execution and Order 28 rule 40 — Discretion of appellate court to respect lower court but to assess risk of injustice.
22 May 2018
April 2018
Appellant proved respondent owned/controlled negligently driven bus and succeeds despite lower court's refusal to admit registration evidence.
Civil liability – motor vehicle collision – proof of ownership/control of vehicle (registration AXA 11) – production of documents and attendance under Order 38 RSC – admissibility of vehicle registration certificate – negligence and loss of dependency – effect of insurer’s settlement.
13 April 2018
Whether interlocutory applications belong to the High Court or Supreme Court of Appeal depends on their nature and timing; premature, deliberate breaches are dismissed.
Civil procedure — interlocutory applications in appeals — Order I r18 (first bring to Court below) — Order III r19 (Court seized after appeal entered) — premature filing of motions in Supreme Court of Appeal — deliberate non-compliance and refusal to waive under Order V r1.
13 April 2018
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
January 2018
Application for stay pending appeal refused for lack of leave to appeal and absence of special circumstances; costs awarded to respondent.
Stay pending appeal – requirement for leave to appeal under Supreme Court of Appeal Act – discretionary refusal of stay; risk of injustice and prejudice test – competing interlocutory orders and abuse of process – availability of damages as alternative remedy.
9 January 2018