Malawi Supreme Court of Appeal - 2021

21 judgments

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21 judgments
Citation
Judgment date
December 2021
Appeal granted and stay ordered on serious questions about magistrate referrals and reopening trial to take fresh pleas.
Criminal procedure — High Court review powers (Courts Act ss.25,26) — Appealability to SCA — Magistrate referrals — Amendment of charges and requirement to take fresh pleas (CP&EC s.151(4)-(5)) — Cure of procedural failures by s.3 CP&EC — Stay pending appeal.
17 December 2021
Application for stay pending appeal refused; applicant failed to prove that refusal would cause injustice; fine’s size alone insufficient.
Civil procedure – stay of execution pending appeal – discretionary remedy – burden on applicant to show on balance of probabilities that refusal causes injustice; size of fine alone insufficient; courts will not grant stay to obtain gratuitous procedural guidance.
10 December 2021
A Registrar must refer contentious, appeal‑likely applications to the assigned judge; an Assistant Registrar’s decision made without referral was void and appeal was incompetent.
Civil procedure – competency of appeal – appeals under section 21 of Supreme Court of Appeal Act lie from High Court or judge, not Registrar – Order 25 CPR: Registrar’s powers subject to judge’s direction and referral – Registrar must refer contentious or appeal‑likely matters to assigned judge – determination by Registrar without referral may be without jurisdiction.
2 December 2021
November 2021
Summary judgment was improperly granted where injunction defence, third‑party proceedings, and an unliquidated loss‑of‑profits claim required a trial.
Civil procedure – Summary judgment and judgment on admission – Defendant’s affidavit and defence raising triable issues – Third‑party proceedings not an admission of liability – Unliquidated loss of profits requiring assessment – Requirement for reasons in judgment.
30 November 2021
30 November 2021
The claimant’s constitutional challenge to electoral appointments was struck out as res judicata, an appeal in disguise, and an abuse of process.
Constitutional law – electoral commission composition – res judicata – appeal in disguise – jurisdiction of constitutional panel – section 42 General Interpretation Act – section 75 Constitution – locus standi – Civil Procedure (Suits by/against Government) Act s4 notice – ex turpi causa – abuse of process.
26 November 2021
The applicant cannot claim posthumous pain and suffering; respondent liable for loss of dependency and expectation of life damages.
Road-traffic negligence – assessment of damages – loss of expectation of life – loss of dependency (multiplicand and multiplier) – proof of earnings and special damages – posthumous pain and suffering claim inadmissible.
19 November 2021
Court granted a stay of execution pending appeal due to a strong jurisdictional challenge and high likelihood of success.
Stay of execution — discretionary relief — guided by balance of convenience, balance of justice and likelihood of success on appeal; jurisdictional challenge — strong prospect of success may justify stay; execution rendering appeal nugatory; costs to successful applicant.
10 November 2021
A party must first seek stay of execution from the lower court; SCA vacated an ex-parte stay for non-exhaustion of remedies.
Civil procedure – appeals – interim relief – stay of execution pending appeal – Order 1 Rule 18 requires applications first to be made to Court below – ex-parte stay vacated where lower court had fixed hearing date and remedies not exhausted – section 22(1)(d) SCA Act inapplicable for such intervention.
10 November 2021
A suing party cannot invoke an arbitration clause to obtain a stay; the ex parte injunction was vacated and matter remitted.
Arbitration clause — stay of proceedings — suing party cannot rely on arbitration to obtain stay; Interim ex parte injunction — effectively permanent relief — vacated; Legal practitioners — practising licence expiry — documents not automatically invalid; Law firm signature — does not of itself render processes a nullity; Courts' jurisdiction — separability and when stay is appropriate.
3 November 2021
October 2021
Appeal allowed in part: special damages must be pleaded and proving; new‑vehicle price is improper benchmark for second‑hand sale.
Civil procedure — leave to appeal — timing and curable irregularity; Pleadings — general v special damages — necessity to plead and prove special damages; Measure of damages — appropriate benchmark for second‑hand goods; Over‑compensation and assessment of quantum.
28 October 2021
September 2021
Claimants succeed on false imprisonment and costs; malicious prosecution fails for reasonable cause; loss of earnings referred to industrial court.
False imprisonment – defendant’s agent handed claimants to police – liability; Malicious prosecution – requirement of absence of reasonable and probable cause and malice; CCTV and investigative evidence as basis for reasonable cause; Referral of loss of earnings/unfair dismissal claims to Industrial Relations Court; Costs awarded where defendant failed to challenge uncontested evidence.
6 September 2021
July 2021
7 July 2021
June 2021
Appeal dismissed with costs for failure to comply with Practice Direction and to prosecute the appeal.
Civil procedure — non-compliance with Practice Direction No.1 of 2010 — failure to file skeleton argument/chronology/list of authorities — dismissal for failure to prosecute — injunction proceedings.
22 June 2021
Appeal dismissed where appellants failed to comply with pre-hearing protocols, indicating abandonment and wasting court time.
Civil procedure — Compliance with Practice Direction No.1 of 2010 — Failure to file skeleton arguments, chronology and authorities — Inference of abandonment — Dismissal of appeal for failure to prosecute — Costs.
6 June 2021
Whether jointly-acquired matrimonial land vests in the surviving spouse by survivorship or forms part of an intestate estate.
Constitutional property rights — section 24(1)(b)(i),(ii) — interpretation of “property held jointly during marriage” — matrimonial property and survivorship — Deceased Estates (Wills and Inheritance) Protection Act — Marriage, Divorce and Family Relations Act — inter vivos dispositions vs intestacy — survivor’s proprietary rights — need for letters of administration.
6 June 2021
Jointly acquired matrimonial property vested in the surviving spouse by survivorship; no administration necessary; section 24 mandates broad fair-disposition principles.
Constitutional and family property law — Interpretation of section 24 (property rights of women) — Meaning of "property held jointly" — Survivorship of jointly held property — Scope of Deceased Estates (Wills and Inheritance) Protection Act and Marriage, Divorce and Family Relations Act — Administration of estates and requirement for letters of administration.
6 June 2021
April 2021
A sentencing rehearing in the High Court is the appropriate constitutional remedy for sentences imposed under the invalid mandatory death provision.
Constitutional law — mandatory death penalty — Kafantayeni and Yasini — remedy of sentencing rehearing under ss. 46(2)–(3) and 108(2) — res judicata and stare decisis inapplicable to constitutional resentencing remedy — reception of post-conviction mitigation evidence — management directions for resentencing.
28 April 2021
21 April 2021
13 April 2021
An appeal from the Industrial Relations Court must raise questions of law or jurisdiction, not re-litigate factual findings.
Labour law – Appeals from Industrial Relations Court – Section 65(2) LRA confines appeals to questions of law or jurisdiction; factual findings of IRC final and binding – Appellate consideration of facts limited to assessing whether law was correctly applied to found facts – Procedural requirements for grounds of appeal (Order III r.2 SCA Rules) – Inchoate appeals.
13 April 2021