Malawi Supreme Court of Appeal - 2023 July

11 judgments

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11 judgments
Citation
Judgment date
July 2023
An applicant's request to release tax‑seized stock pending litigation was dismissed for procedural defects and unstated legal basis.
Tax law — seizure of goods — interim injunction to release impounded stock pending litigation; Civil procedure — competency of proceedings in appellate courts — requirement to state legal basis for relief; Procedural irregularity — standalone application in appellate court.
26 July 2023
Whether an interim injunction should release impounded stock pending tax proceedings to prevent irreparable business harm.
Interim relief – Injunction pending tax proceedings – Release of goods impounded by revenue authority – Irreparable harm and adequacy of damages – Balance of convenience and public interest.
26 July 2023
Appeal dismissed: 20 April 2016 letter was a binding contract, debt discharged by MK16,304,708.82, respondent entitled to interest.
Contract — variation of existing loan agreement by letter — formation, offer, acceptance and consideration — discharge of debt by payment of shortfall; Civil procedure — compliance with Order III grounds of appeal; Interest on judgment — pleadings, statutory rate and assessment by Registrar.
18 July 2023
Stay of execution refused where applicants failed to show respondent’s inability to repay or irreparable harm.
Stay of execution pending appeal — tests: serious issue to be tried, irreparable harm, balance of convenience/justice — impecuniosity evidence required — criminal prosecution allegations speculative and irrelevant to civil stay.
18 July 2023
Court continued ex parte stay pending appeal, granted leave to appeal, and ordered procedural steps and exclusion of later punitive orders.
Civil procedure – stay of execution pending appeal – jurisdiction under Order 1 Rule 18 – inherent jurisdiction – test for stay: justice, expediency, risk of appeal being rendered nugatory, balance of convenience – leave to appeal granted – exclusion of later punitive orders from record of appeal.
14 July 2023
Court sustained stay pending appeal, granted leave to appeal, and ordered timelines while excluding un-heard punitive orders from the record.
Civil procedure — Stay of execution pending appeal — Discretionary equitable remedy — Tests: serious issue, irreparable harm, balance of convenience/justice — Jurisdiction under Order 1 Rule 18 and inherent jurisdiction — Leave to appeal and exclusion of unhearing punitive orders from record.
14 July 2023
Court continued stay pending appeal, granted leave to appeal, and excluded un-heard post-judgment punitive orders from the record.
Civil procedure — Stay of execution pending appeal — Jurisdiction of appellate single judge to entertain stay before lower court final determination — Test for stay: serious issue, irreparable harm, balance of convenience/justice — Leave to appeal — Exclusion of post-judgment punitive orders from record where parties were not heard.
14 July 2023
Supreme Court dismissed stay, leave to appeal and extension applications for procedural non-compliance and premature filing.
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10 July 2023
Supreme Court dismissed stay and out‑of‑time leave applications for failure to comply with High Court‑first procedural requirements.
Civil procedure – interlocutory orders – stay of execution pending appeal – requirement to first seek relief in High Court (Order I r.18) – incompetence of affidavit evidence – leave to appeal out of time and extension of notice period – procedural non‑compliance fatal.
10 July 2023
The SCA refused ex parte relief, holding the High Court's order for an inter partes hearing was proper case management.
Immigration — Deportation v valid residence permit; Judicial review — leave to move and interim injunctions; Civil procedure — ex parte v inter partes hearings; Case management — wide discretion under CPR; Appellate review — interference only if legal error or clearly wrong.
4 July 2023
Applicant must first have High Court determine judicial review and injunction; appellate interference with case-management orders is unwarranted.
Immigration and deportation — Judicial review — Leave to apply and interim injunctions — Ex parte relief exceptional — Case-management discretion under CPR — Appellate restraint on interfering with lower court's exercise of discretion.
4 July 2023