Malawi Supreme Court of Appeal - 2023

47 judgments

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47 judgments
Citation
Judgment date
December 2023
SCA application dismissed for lack of jurisdiction and for failing to first pursue the required Court below proceedings.
Supreme Court of Appeal jurisdiction – Section 7 SCA Act – Order 1 Rule 18 SCA Rules – requirement to apply first to Court below – disguised appeal – inherent jurisdiction not a substitute for procedural compliance.
22 December 2023
Single-member court refused an ex parte stay where the lower court had not refused and the affidavit lacked disclosure.
Civil procedure — Order 1 r18 — application must first be made to court below; adjournment ≠ refusal; ex parte applications — duty of full disclosure; inadmissible hearsay; powers of single member under section 7 of the Supreme Court of Appeal Act.
13 December 2023
Refusal of leave for judicial review is not appealable; a stay pending appeal requires the correct enabling provisions and procedure.
Civil procedure – Stay pending appeal – Enabling provisions – Section 7 Supreme Court of Appeal Act – Order I r18 SCA Rules – Part 52.16 CPR – Refusal of leave for judicial review not appealable; remedy is to reapply to a single member – Stay against enforcement requires Part 54.12/Order 19 r20.
12 December 2023
November 2023
Application dismissed for failing Order I, rule 18 and for inordinate delay; costs awarded against the applicants.
Procedure — Order I, rule 18 SCA Rules — concurrent jurisdiction — same application must be first made to court below; delay and introduction of post‑order facts bar relief. Civil procedure — stay of execution/payment into court — discretionary, requires good grounds (risk of dissipation, non‑recovery). Labour law — section 72 LRA limits IRC’s power to award costs but does not preclude High Court/SCA awarding costs on appeals Costs — appellate courts have discretion to award costs in labour appeals
10 November 2023
Delay and applicants’ failure to mitigate justified refusal of extension, dismissal of judicial review permission, and refusal of stay.
Judicial review – permission to apply – extension of time – unjustified 16‑month delay and failure to mitigate – forum misstated; matters better determined at trial – refusal of interlocutory stay of criminal proceedings.
10 November 2023
Applicants’ 16‑month delay and failure to mitigate precluded extension; issues suited to trial court, so judicial review application dismissed.
Judicial review — permission to apply; extension of time — 3‑month rule; interlocutory stay of criminal proceedings; delay attributable to applicant/counsel; appropriateness of judicial review versus trial court remedy.
10 November 2023
October 2023
Application for leave to seek judicial review dismissed for inordinate delay and lack of arguable legal interest.
Judicial review – leave to apply – extension of time – inordinate delay – locus standi/legal interest – alternative remedies under Financial Services Act – procedural fairness and merits of administrative decision.
23 October 2023
Security-for-costs order in a labour appeal set aside because section 72 bars costs and such security would be futile.
Labour law – costs – section 72 Labour Relations Act proscribing costs in Industrial Relations Court and on appeal – security for costs – Supreme Court discretion under section 22 of the Supreme Court of Appeal Act and Rules – ex parte security-for-costs order set aside as futile.
23 October 2023
Bail pending appeal denied—no exceptional circumstances and court declined to resolve appeal merits at bail stage.
Criminal law – Bail pending appeal – s24(1) Supreme Court of Appeal Act – discretionary power; exceptional circumstances required – appellate court should not decide merits at bail stage – defilement conviction; sufficiency and consistency of trial evidence.
19 October 2023
August 2023
Interlocutory vacatur of injunction is inchoate and not appealable; stay pending appeal refused where debtor owes secured debt.
Civil procedure – Stay of execution pending appeal – Interlocutory orders and inchoate decisions – Appealability – Proper procedure (Order 1 R.18 and Order 2 R.1 Supreme Court Rules) – Balance of convenience and risk of injustice – Security for debt and repossession of pledged vehicles – Nugatory appeal doctrine.
7 August 2023
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.
:[
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
June 2023
9 June 2023
A stay pending appeal was refused because applicants delayed prosecution despite raising serious appellate issues.
Criminal procedure — Stay of proceedings pending appeal — Discretion to grant stay — Delay in prosecuting appeal — Judge's refusal to hear matter de novo after transfer — Jurisdictional challenge.
9 June 2023
The SCA lacks jurisdiction to hear a direct appeal from an Assistant Registrar’s interlocutory order; such appeals lie first to a High Court Judge.
Civil Procedure – Jurisdiction of the Supreme Court of Appeal – Appeals from Registrar/Assistant Registrar decisions – Interlocutory orders – Order 25 CPR – Section 21 Supreme Court of Appeal Act – Appeal to Judge in chambers before SCA – Assessment of costs/insurance policy limits (merits not decided).
8 June 2023
Permission for judicial review of arrest/prosecution granted; interim suspension denied; confiscated passport ordered returned.
Judicial review – reviewability of decisions to arrest and prosecute – permission to apply for review; interim relief; abuse of prosecutorial discretion; procedural error in lower court.
8 June 2023
May 2023
Appeal dismissed for failure to comply with Order III rules and for filing judicial review two years after the prescribed period without extension.
Civil procedure — Appeal grounds must comply with Order III rules 2–4 (state law or fact and particulars); Judicial review applications must be brought promptly and within three months under Order 53(4)(1) unless time is validly extended; Non-compliance and lack of extension renders review/application time-barred and appeal liable to dismissal.
4 May 2023
March 2023
Court vacated stay pending appeal, finding appellant failed to show appeal would be rendered nugatory and balance of justice favoured respondents.
Civil procedure – stay pending appeal – discretionary power of appellate court – tests: serious issue, irreparable harm, balance of convenience; jurisdiction of High Court vs. statutory tribunal; alleged illegality, irregularity and excess of jurisdiction; costs.
28 March 2023
Applicants granted seven‑day enlargement to appeal after registry failures and missing leave order justified extension.
Civil procedure — Extension of time to appeal — Order III r 4 Supreme Court of Appeal Rules — Good and substantial reasons — Registry negligence and missing filed documents — Competency vs. final dismissal (functus officio) — Use of eCMS as evidence of mismanagement.
8 March 2023
Registry failings causing lost filings can justify an enlargement of time to appeal where no final adjudication on the merits occurred.
Civil procedure – enlargement of time to appeal – section 23(2) Supreme Court of Appeal Act and Order III r 4 – good and substantial reasons – registry negligence and lost filings – functus officio and abuse of process distinguished – reliance on eCMS records.
8 March 2023
Court granted seven‑day extension and leave to appeal after accepting registry negligence and prima facie arguable grounds.
Civil procedure – enlargement of time to appeal – Order III r 4 and s.23(2) Supreme Court of Appeal Act – good and substantial reasons – registry negligence and lost filings – eCMS evidence – functus officio and abuse of process – distinction between dismissal for want of competence and final decision.
8 March 2023
February 2023
Table 6 collection charges are solicitor–client charges payable by the client, not recoverable from the debtor once proceedings commence.
Legal practitioners' fees — Table 6 collection charges — solicitor-and-own-client charges on receipt of monies; not recoverable from judgment debtor after commencement of proceedings; pleading of costs; effect of Government Notices and Law Revision Orders.
14 February 2023
A settlement agreement constituting a final order bars interlocutory appeals; amendment motion was incompetent and appeal dismissed.
Commercial procedure – settlement agreement – final order – interlocutory application – O.18 High Court (Commercial Division) Rules – s.21 Supreme Court of Appeal Act – res judicata – leave to amend pleadings – leave to appeal.
14 February 2023
Eyewitness and medical evidence established malice aforethought; convictions and 15‑year sentences were upheld.
Criminal law – Murder – Malice aforethought (s.212 Penal Code) – Eyewitness reliability – Direct evidence – Post‑mortem medical evidence – Mob assault – Sentence review – Manifest excessiveness.
14 February 2023
Eyewitness and medical evidence proved murder with malice aforethought; convictions and 15-year sentences affirmed.
Criminal law – Murder – Eyewitness credibility – Corroborating post-mortem evidence – Malice aforethought under Section 212 (knowledge or intention/probable consequence) – Joint participation in a prolonged assault – Sentence affirmed.
14 February 2023
Whether eyewitness evidence proved appellants’ malice aforethought in fatal mob assault; appeal dismissed.
Criminal law – Murder – Malice aforethought under s.212 (knowledge of probable death/grievous harm or intention to commit felony) – Eyewitness credibility despite limited inconsistencies – Causation established by post-mortem – Sentence proportionality.
14 February 2023
Application for judicial review withdrawn as underlying interdict became moot; no order as to costs.
Judicial review – withdrawal of application – mootness following dismissal of underlying criminal charges – injunction/interdict rendered nugatory – noting withdrawal – no order as to costs where counsel acted pro bono.
13 February 2023
Application for judicial review and injunction withdrawn as underlying charges were dropped; no order as to costs.
Judicial review – leave and interlocutory injunction rendered moot by dismissal of underlying criminal charges – withdrawal of application – costs where parties act pro bono.
13 February 2023
Court compelled issuance and settlement of appeal record, set strict timelines, lifted stay, and penalized appellants' inactivity.
Civil procedure — dismissal for want of prosecution; duty to settle the record and file skeleton arguments (Practice Direction No.1/2010); stays of execution do not excuse prosecution delays; court may compel Registrar to issue documents and set timelines; costs awarded for non-compliance.
8 February 2023
A single-judge court will not vary a preservation order where the same issue is the subject of a pending appeal; follow Order 1 Rule 18.
Financial Crimes Act — preservation orders — variation of preservation orders; Appellate procedure — Order 1 Rule 18 — concurrent jurisdiction; Single-judge powers — stay and variation pending appeal; Procedural impropriety — circumventing appeal process.
8 February 2023
Supreme Court lacks jurisdiction to vary Financial Crimes Act Preservation Orders; application dismissed with costs.
Financial Crimes Act – Preservation Orders – Section 71 – Variation/rescission powers vested in the court that made the order (High Court) – No concurrent jurisdiction in Supreme Court of Appeal – Order 1 Rule 18 inapplicable – Single-judge intervention inappropriate where appeal pending.
8 February 2023
Applicant prematurely sought leave to appeal to the Supreme Court without first applying to the High Court; application dismissed.
Civil procedure — Leave to appeal — Order 1 Rule 18 SCA Rules — Application must first be made to court below — Premature application while assessment ruling pending — Default judgment proceedings.
8 February 2023
8 February 2023
Failure to timely file required skeletal arguments justified vacatur of a stay of execution pending appeal; SCA had jurisdiction under Order III r.19.
Appeal procedure; Order III r.19 — jurisdiction of SCA after an appeal is entered; Practice Direction No.1 of 2010 — filing skeletal arguments; failure to prosecute appeal; vacatur of stay of execution; costs awarded to respondent.
7 February 2023
January 2023
Ex parte stay refused where urgency related to counsel’s personal interests and counsel was not a party to the appealed proceedings.
Civil procedure — Stay pending appeal — Discretionary relief requiring special circumstances; ex parte applications; standing — non-party legal practitioner cannot seek stay to protect personal interests; criminal review proceedings.
12 January 2023
Court refused ex parte stay pending appeal where claimed prejudice affected counsel, not the applicant, and no special circumstances shown.
Criminal procedure — Stay pending appeal — Ex parte applications — Applicant must show special circumstances — Non-party (legal practitioner) cannot seek stay to protect own interests — Stay should not revive subordinate court proceedings unjustly.
12 January 2023
Court dismissed ex parte stay as alleged urgency concerned the applicant’s counsel, a non‑party, not the parties to the appeal.
Criminal procedure — Stay of execution pending appeal — discretionary remedy — special circumstances required — ex parte application — non‑party’s interest — counsel cannot seek relief in applicant’s name.
12 January 2023
A stay pending appeal was refused where urgency related to the applicant’s non-party lawyer, not the applicant, and no special injustice was shown.
Criminal procedure — stay pending appeal — ex parte application — discretionary stay — non-party legal practitioner lacks standing to seek relief in applicant's name — protection of successful litigant's fruits of judgment.
12 January 2023