Malawi Supreme Court of Appeal

375 judgments
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Results. 375 judgments found.

375 judgments
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
November 2020
16 November 2020
5 November 2020
October 2020
2 October 2020
September 2020
30 September 2020
August 2020
24 August 2020
24 August 2020
21 August 2020
Convictions for forgery and attempted theft confirmed; forgery sentence reduced, lawyer admonished and referred for disciplinary inquiry.
  • Criminal law — Forgery of court instruments — Sentence review and reduction — Plea of guilty and mitigation — Automatic review without oral hearing under s.363(2) (COVID‑19) — Professional misconduct: admonition and referral to Disciplinary Committee under Legal Education and Legal Practitioners Act.
13 August 2020
Registrar has discretion on counsel numbers; care and conduct allowed and taxed at 100%, with specified sums payable in 30 days.
  • Costs taxation — Registrar's discretion on number of counsel; care and conduct fees allowable under Courts (High Court) (Civil Procedure) Rules, 2017; percentage uplift for care and conduct — 100% awarded for a complex appeal; payment within 30 days.
10 August 2020
July 2020
Appellate court found instalment order unsupportable without full disclosure and ordered fresh financial inquiry.
  • Civil procedure — Payment of judgment debt by instalments — Order 28 r.62 — full, frank and honest disclosure of debtor's means — balancing creditor and debtor interests — appellate review of discretionary orders — trading debt.
29 July 2020
Court allowed appeal—instalment order set aside for insufficient disclosure and failure to balance creditor’s interest; matter remitted for full financial determination.
  • Civil procedure — Payment of judgment by instalments — Order 28 rule 62 — Full, frank and honest disclosure of debtor’s means — Balancing creditor and debtor interests — Discovery from non-parties — Appellate interference with discretionary orders.
29 July 2020
Convicted prisoner granted bail pending appeal due to excessive five-year delay; COVID-19 risk insufficient for serious murder sentence.
  • Criminal procedure — Bail pending appeal — Post-conviction bail requires applicant to show special/exceptional circumstances — Prolonged delay in delivery of appeal judgment as ground for bail — COVID-19 risk not automatically sufficient for serious offences — Conditions: bond, deposits, sureties, surrender of travel documents, reporting and travel restrictions.
10 July 2020
A bona fide purchaser’s court‑sanctioned, registered property cannot be seized; seizure varied and rents restored to the appellant.
  • Corrupt Practices Act — seizure and freezing warrants; Registered Land Act s.25 — protection of proprietor and bona fide purchaser; ex parte applications and disclosure of material facts; ‘‘technical dissipation’’ unsupported; inordinate prosecutorial delay; variation of seizure and restoration of funds.
1 July 2020
May 2020
Court annulled presidential return for pervasive procedural irregularities, held majority means 50%+1 of votes cast, ordered fresh election and costs against the Commission.
  • Electoral law — burden and standard of proof in election petitions (prima facie burden on petitioner; evidential shift to Commission on balance of probabilities) — irregularities (Tippex/altered, duplicate/fake/uncustomised/reserve/unsigned tally sheets; unlawful Constituency Tally Centres; unresolved complaints) — Commission's quasi-judicial complaints power non-delegable — interpretation of 'majority of the electorate' (section 80(2)) as 50% + 1 of votes cast — Attorney General's role in constitutional referrals.
8 May 2020
February 2020
18 February 2020
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.
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7 February 2019
November 2018
An appeal is premature where liability is decided but damages remain unassessed; only final judgments are ordinarily appealable.
  • Civil procedure — Appeals — Finality — Appeal premature where lower court has decided liability but damages remain unassessed; inchoate/non‑enforceable judgments not ordinarily appealable; costs in the cause.
29 November 2018
An appeal on liability is premature if damages remain unquantified and the judgment below is inchoate; appeal delisted.
  • Civil procedure — Appeal — Premature appeal where damages remain unquantified — Inchoate judgment not immediately enforceable — Appeals should follow final determination of liability and quantum — Appeal delisted; costs in the cause.
29 November 2018
Summary judgment improperly entered amid disputed negligence and valuation; appeal allowed and matter remitted to Commercial Division for full hearing.
  • Civil procedure — Summary judgment — Improper entry and confirmation where negligence and valuation were disputed; Commercial jurisdiction — matter remitted to High Court Commercial Division for full and expedited hearing.
28 November 2018