Malawi Supreme Court of Appeal - 2019

20 judgments

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20 judgments
Citation
Judgment date
November 2019
Stay application dismissed as premature; notice of appeal struck out for failure to serve and prosecute.
Civil procedure — stay pending appeal — prematurity where no enforcement order obtained; Order I r18 — first seek stay in lower court; failure to serve notice of appeal and to prosecute appeal — striking out; failure to serve skeleton arguments — sanction.
7 November 2019
August 2019
Whether interlocutory and case-management decisions are appealable and should be interfered with; appeal dismissed with costs.
Appealability — Sections 21 and 23 Supreme Court of Appeal Act; procedural requirements — Notice of Appeal; interlocutory orders and case-management; appellate interference with exercise of judicial discretion; dismissal with costs.
15 August 2019
July 2019
High Court lacked jurisdiction; Director immune absent bad faith; regulations and closure orders were lawful and reasonable.
Environmental law — Director’s statutory immunity; prerequisite to sue: proof of bad faith — Jurisdiction: requirement to exhaust Environmental Appeals Tribunal remedies before High Court judicial review — Subsidiary legislation reviewable for reasonableness (Kruse/Wednesbury) but courts defer to policy and local circumstances — International instruments (Basel, SADC) enable domestic regulation, do not impose specific micrometer standards.
31 July 2019
Applicant failed to prove respondent liable for crop loss from experimental barn due to lack of evidence and agency link.
Contract farming – agronomy services – experimental tobacco barns – agency – vicarious liability – negligence – particulars of negligence – burden of proof – causation – quantum of loss.
19 July 2019
High Court lacked jurisdiction after an Ombudsman determination; the correct remedy was review under section 123(2), so appeal dismissed.
Administrative law — Ombudsman determinations — compliance or judicial review under section 123(2) of the Constitution — jurisdiction of High Court — forum-shopping and nullity of proceedings where review remedy available.
17 July 2019
High Court lacked jurisdiction over a dispute already determined by the Ombudsman; review under the Constitution was the proper remedy.
Administrative law — Ombudsman determinations — must be complied with or reviewed under Constitution s123(2); forum shopping prohibited; High Court lacked jurisdiction; proceedings nullity.
17 July 2019
High Court may vary Supreme Court bail conditions for good cause, but Hajj travel denied due to flight risk.
Bail – Variation of conditions – High Court’s power to vary bail conditions granted by superior court – Flight risk – Travel for religious pilgrimage (Hajj) refused.
10 July 2019
June 2019
26 June 2019
April 2019
Court taxed the claimant’s costs after itemised reductions, awarding K4,310,584.75 in recoverable costs.
Costs — taxation — standard basis — reasonableness and proportionality of items; hourly rate; instruction fees on assessment proceedings; disallowance of duplicate discovery items; allowance for out‑of‑court negotiations; general care and conduct set at 50%.
23 April 2019
16 April 2019
February 2019
Ex parte leave for judicial review requires a prima facie arguable case; ministerial appointments/commissions are generally non‑justiciable and NGOs lacked standing.
Judicial review — leave to apply — prima facie/clearly arguable case required; Executive powers/prerogative — reviewability depends on subject‑matter and justiciability; Appointment/suspension of ministers and appointment of commissions of inquiry generally non‑justiciable absent statutory/constitutional underpinning or infringement of individual rights; Locus standi — NGOs must show a particular legal interest affected; Affidavit/mandate — deponent must demonstrate authority to represent trustee organisations.
13 February 2019
Loss-of-use damages compensate unavailability of a chattel when called upon, not only days it was actually used; mitigation limits period.
Sale of Goods/Consumer Protection – breach of contract – damages for loss of use of a chattel – measure and period of loss-of-use; mitigation by purchase of replacement; assessment of damages beyond sporadic actual use.
13 February 2019
First appellant’s convictions for misuse of public office and neglect upheld; second appellant’s convictions on uncharged counts quashed.
Corrupt Practices Act s25B(1) – misuse of public office; Penal Code s121 – neglect of duty; prima facie threshold at close of prosecution; circumstantial evidence and chain of inference; admissibility of secondary/public documents; conviction not permissible for offences not charged.
13 February 2019
Whether bail pending appeal should be granted; court may grant pre-hearing bail and virtual hearings can satisfy public-trial requirements.
Criminal procedure – Bail pending appeal – Interpretation of section 24 Supreme Court of Appeal Act – Applications not necessarily premature pre-hearing; Public trial – virtual/remote hearings and constitutional public-access requirement; Exercise of discretion – consider all circumstances (Macdonald Kumwembe); Alleged trial irregularities and health claims require substantiation.
13 February 2019
Acquittal where identification was unreliable and the prosecution failed to disprove the applicant’s alibi.
Criminal law – Murder – Identification evidence and Turnbull guidelines for dock recognition – Alibi defence and burden on prosecution to disprove alibi – Insufficiency of circumstantial evidence – Acquittal for reasonable doubt – Police investigative failures.
12 February 2019
Conviction quashed where identification was unreliable, the alibi was not disproved and the State failed to prove weapon issuance or deployment.
Criminal law — identification evidence — dock recognition — Turnbull principles — alibi defence — burden on prosecution to disprove alibi — circumstantial evidence insufficiency — failure to prove issuance/deployment of weapon — conviction quashed.
12 February 2019
Retrenched employees entitled to reassessed individual compensation; severance payments under s35 deductible from awards.
Employment law – retrenchment and unfair dismissal – consultation requirements; Section 57(2) (capacity/conduct) – limited application to redundancy; Section 61(2) – justice and equity in dismissal; Section 35 – severance allowance independent and deductible from compensation; assessment of damages – individualised assessment required.
11 February 2019
11 February 2019
Whether appellants benefited from a later amendment to sentencing law (lex mitior); court held amendment not milder and dismissed appeal.
Criminal law – sentencing – lex mitior (retroactive application of milder penal law) – General Interpretation Act s14 (savings on repeal and re‑enactment) – theft by public servant – mandatory minimum sentences – appellate limits under S.11(2) Supreme Court of Appeal Act.
7 February 2019
Amendment to Penal Code did not confer retroactive benefit; appeal limited to law, conviction and sentence confirmed.
:[
7 February 2019