Malawi Supreme Court of Appeal - 2022

30 judgments
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Results. 30 judgments found.

30 judgments
December 2022
Appeal dismissed for non‑compliant, vague grounds of appeal; procedural rules breach precluded hearing merits.
  • Civil procedure — Appellate practice — Order III, rule 2 — Grounds of appeal must be concise, precise and indicate whether based on law or fact — Vague or argumentative grounds may be struck out
  • Procedure — Non‑compliance with appeal rules constitutes want of due prosecution and may result in dismissal
  • Discretion — Court may waive non‑compliance only in exceptional circumstances and in interests of justice
20 December 2022
Whether shareholders’ resolutions cured JVA breaches and minority shareholders’ rights (including dividend distribution) must be protected.
  • Company law — Joint Venture Agreement — equity contributions and subscription mechanics — shareholder/board resolution effect; Corporate governance — protection of minority shareholders; Civil procedure — amendment of pleadings after close of case; Evidence/admissibility — role of independent equity verification reports (PWC) and limits on re‑opening judgments; Companies Act — orders affecting share register and dividends; Remedies — accounting, restitution and restoration of shareholding ratios.
14 December 2022
Proceedings stayed because amici curiae were admitted without mandatory service and hearing of the Attorney General.
  • Constitutional procedure — admission of amici curiae — mandatory service on Attorney General (Order 19 r8) — procedural irregularity; Supreme Court single‑judge jurisdiction (s.7 SCA Act; Order 1 r18); inherent jurisdiction to stay to prevent appeal becoming nugatory.
2 December 2022
November 2022
Court refused to re-enter an appeal dismissed for non-attendance, finding no jurisdiction or sufficient cause.
  • Civil procedure — non-appearance — Order III rule 21(2) (re-entry applies to struck out appeals only) — insufficient cause for non-attendance — inherent jurisdiction — functus officio — delay and prejudice.
10 November 2022
Application to re-enter an appeal dismissed for non-attendance refused: court lacked jurisdiction, dismissal rendered it functus officio, and appellant showed undue delay.
  • Civil procedure — Appeal dismissed for non-appearance — Order III r.21(2) permits re-entry for struck-out appeals but not dismissed appeals; inherent jurisdiction limited; dismissal renders court functus officio; insufficient cause where counsel’s explanation is inconsistent; prior delay and lack of diligence relevant to discretion.
10 November 2022
October 2022
Applicant failed to show exceptional circumstances for bail pending appeal based on alleged conflicting authorities on licence burden.
  • Bail pending appeal — exceptional circumstances required — applicant must show likelihood of success on appeal.
26 October 2022
Court refused stay pending appeal, holding the appeal interlocutory and case-management matters belong to the trial court.
  • Civil procedure — Stay pending appeal — Interlocutory (inchoate) appeals — Case management and discretionary powers of trial court — Amendments after trial — Reluctance of appellate court to interfere.
26 October 2022
Whether dismissal for alleged intoxication at work was substantively and procedurally fair under section 57 of the Employment Act.
  • Employment law — unfair dismissal — section 57 (valid reason and substantive fairness) — disciplinary procedure — disciplinary hearings not courts — availability of accusers for cross‑examination only on request — employer’s duty to give reasons arises during disciplinary proceedings — trial may proceed in absence of a party — forum jurisdiction and costs.
13 October 2022
Dismissal for alleged drunkenness upheld; disciplinary process found substantively and procedurally fair; appeal dismissed, costs awarded.
  • Employment law — unfair dismissal — disciplinary hearing — consuming alcohol on duty — substantive and procedural fairness — section 57 and section 62 Employment Act — right to cross-examine accusers — court proceeding in absentia.
13 October 2022
Failure to attend court-ordered mediation justified dismissal; appellate interference requires proof of abuse of discretion.
  • Civil procedure — Mediation — Order 13 r.6 of the Courts (High Court) (Civil Procedure) Rules 2017 — Dismissal for failure to attend mediation — Judicial discretion in case management — Appellate interference only for abuse of discretion; appellate grounds must comply with Order 111 r.2.
6 October 2022
September 2022
Court allowed amendment of grounds and limited fresh documentary evidence alleging perceived judicial bias, distinguishing bias from misconduct.
  • Civil procedure — Leave to amend Notice and Grounds of Appeal — Court’s discretion to allow amendments at any stage — Fresh evidence on appeal — admissibility test (reasonable diligence and materiality) — Single-member jurisdiction to hear procedural leave applications — Allegations of perceived bias distinct from judicial misconduct — Judicial Service Commission not sole forum for appellate consideration of bias-related grounds.
26 September 2022
August 2022
Time to appeal runs from receipt of judgment copies; appeal not out of time and must proceed to full bench.
  • Appeal procedure — computation of time to appeal: time runs from receipt of judgment copy by parties; leave to appeal required for chamber judgments — leave obtained from High Court following prior direction; single member lacks jurisdiction to dismiss substantive appeals; application to strike out for being out of time dismissed.
17 August 2022
July 2022
Application to reopen SCA judgment dismissed for procedural non-compliance and absence of exceptional grounds.
  • Civil procedure — enforcement of practice directions — late filing of skeleton arguments, failure to lodge authorities and chronology — application dismissed; Supreme Court of Appeal — limited power to review its own final judgments (clerical error or exceptional circumstances such as bias, fraud, jurisdictional defect); finality in litigation.
28 July 2022
11 July 2022
June 2022
The applicant’s claim failed: racist insults about driving were offensive but not legally defamatory; appeal dismissed.
  • Defamation — ordinary and ordinary‑meaning test; whether insulting/racial remarks constitute defamatory imputation of character or mere abuse; requirement of proof of reputational harm; vicarious liability — scope of employment not determined where no defamation established.
30 June 2022
Bureaucracy or absent counsel do not justify extending time to appeal; applicant must show substantial reasons and prima facie meritorious grounds.
  • Civil procedure — Extension of time to appeal — applicant must show good and substantial reasons for delay and prima facie meritorious grounds; internal bureaucracy or absent counsel insufficient; compliance with Order III rules on Notice and grounds of appeal; summary judgment challenges.
14 June 2022
May 2022
Whether corruption reverse‑onus provisions unlawfully shift legal burden and infringe the applicant's presumption of innocence.
  • Constitutional law — Corrupt Practices Act s.32(2)(b),(c) — reverse onus — distinction between legal (persuasive) and evidential burdens — presumption of innocence and right to silence (s.42(2)(f)(iii)) — limitation and proportionality under s.44 — statutory interpretation in context of anti‑corruption objectives.
17 May 2022
April 2022
Refusal to adjourn and entering judgment without a merits hearing risked denial of a fair trial; judgment set aside and matter remitted.
  • 'Adjournment' — judicial discretion — overriding objective of Civil Procedure Rules — refusal of adjournment — denial of fair trial; 'Default judgment' — entering judgment without hearing merits; appellate review of discretionary orders.
26 April 2022
Court upheld trial judge’s discretion in refusing stay of criminal proceedings pending judicial review.
  • Judicial review — stay of criminal proceedings — injunction discretionary — adequacy of damages as remedy — standard of appellate review of discretionary decisions — balance of convenience and public interest — double jeopardy allegation.
19 April 2022
19 April 2022
Court outlines required papers and formalities for grants of administration and allows special-purpose grants for pending litigation.
  • Probate procedure — Applications for letters of administration — Required papers: Oath for Administrator, administration bond, proof of death, certified estate duty affidavit and certificate, draft grant, copy of applicant ID — Forms must be followed; special-purpose grants for pending litigation permissible under s50(1).
15 April 2022
Where a service contract is terminable on three months' notice, contractual damages are ordinarily limited to that three‑month period.
  • Contract — termination by notice — damages limited to notice period; Damages — general v special — pleading and proof of loss of profits; Defamation actionable per se — general damages for reputation and loss of patronage; Interest — court may award compound interest at common law; Payment into court — non‑disclosure rule and procedural irregularity.
6 April 2022
An appeal against an order made in chambers was incompetent: leave was required and the notice of appeal was filed out of time.
  • Civil procedure — Appeal competence — Leave required for orders made in chambers (s.21 SCAA Act) — Notice of appeal filed out of time — Lower court lacked jurisdiction to extend time to appeal (s.23(2)) — Caution on ex-parte applications after long delay.
5 April 2022
March 2022
The applicant's claim against the respondent bank failed because the applicant's conduct facilitated the cheque forgeries.
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31 March 2022
Appellant entitled to remedy for non-delivery: contract enforceable despite unresolved duty-free status; refund with interest and MK10,000,000 damages ordered.
  • Sale of Goods Act — contract of sale versus agreement to sell — specific goods in deliverable state — specific performance as equitable remedy — separation of purchase price and customs duty — damages for non-delivery.
30 March 2022
February 2022
Convicted appellant granted bail pending appeal due to prima facie prospects of success, likely delay, trial‑fairness concerns and health issues.
  • Criminal law — Bail pending appeal — Section 24 Supreme Court of Appeal Act — Exceptional/unusual circumstances — Prospects of success on appeal — Admissibility and provenance of audio recordings — Circumstantial evidence — Virtual hearings and public trial — Quorum and Practice Direction — Health as factor.
4 February 2022
Bail pending appeal may be granted where prima facie prospects of success and health or delay constitute exceptional circumstances.
  • Bail pending appeal — section 24 SCA Act — discretion exercised in interests of justice — exceptional/unusual circumstances — prospects of success; admissibility and provenance of audio recordings; circumstantial evidence; virtual hearings and public trial; delay/quorum; ill health as special circumstance.
4 February 2022
January 2022
Whether judicial review is the proper route to challenge an IRC judicial order and whether an appellate court may restore interim relief.
  • Judicial review v. judicial decisions; subordinate courts — appeals, review and supervision; s61 Courts Act — judicial immunity absent bad faith; interim relief — balance of convenience and security; appellate jurisdiction to entertain fresh applications.
31 January 2022
Court reinstated IRC interim stay of dismissal, holding judicial review inappropriate for judicial decisions and ordering security.
  • Judicial review v appeals — appropriateness of reviewing judicial decisions; Courts Act s.61 — judicial immunity absent bad faith; interim reliefs and discretionary review; balance of convenience and security for interim relief; case management and duplication of proceedings.
31 January 2022
Appellate court reinstated IRC interim stay, finding High Court misapplied discretion and limiting judicial review of judicial decisions.
  • Civil procedure
    • — Judicial review — Review of judicial decisions of subordinate courts and effect of Courts Act s 61 immunity
    • — Interim relief — Discretion, balance of convenience and when a stay should be granted or vacated
    • — Jurisdiction — Appellate court entertaining fresh applications to challenge interim relief where High Court has granted or refused leave
31 January 2022