Malawi Supreme Court of Appeal

378 judgments
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Results. 378 judgments found.

378 judgments
July 2010
Appeals against costs-only orders require leave; appeals improperly brought and lacking leave were dismissed for want of jurisdiction.
  • Civil procedure — Appeal against costs-only order — Leave required from court below — Scherer principle where judge failed to exercise judicial discretion; Procedural competence — challenging earlier jurisdictional directions must be appealed within time or by leave.
27 July 2010
A subsequent challenge to a sale under a charge was barred by res judicata; fraud or absence do not justify fresh proceedings.
  • Civil procedure — res judicata (cause of action estoppel) — same parties, same issue, same subject matter — new facts/fraud must be raised by setting aside or appeal — absent party with filed defence and skeleton arguments does not necessarily render judgment a default.
8 July 2010
An absent party should ordinarily apply to the trial court to set aside a default judgment; Court of Appeal may only in exceptional cases hear a direct appeal.
  • Civil procedure — Default judgment — Order 35 r.2(1) — Application to set aside judgment — Preferred procedure is application to trial court (preferably trial judge) — Court of Appeal’s discretion to hear direct appeal in appropriate cases — Direct appeal inappropriate where vital evidence not before trial court.
1 July 2010
June 2010
Respondent granted leave to amend notice; appellant's murder appeal dismissed—provocation failed and death sentence upheld.
  • Civil procedure — amendment of respondent’s notice to affirm and vary — Order III r 13(1) — test for leave to amend: issues not on pleadings, absence of supporting evidence, or prejudice — pleadings and lower court findings relevant. Criminal law — murder — partial defence of provocation — sufficiency of evidence and jury direction; sentencing — discretion in imposing death and aggravating conduct warranting capital sentence
30 June 2010
A bona fide purchaser who acquired registered land under court authorisation is protected from seizure absent evidence of dissipation.
  • Property law — Registered land — Proprietor's rights after court‑authorised sale — Protection under s.25 Registered Land Act; seizure and freezing orders — requirement of evidence of dissipation; ex parte applications — duty to disclose material facts; delay and prejudice to bona fide purchaser.
30 June 2010
Whether provocation or mitigation justified overturning the applicant's murder conviction or avoiding the death sentence.
  • Criminal law — Murder — Partial defence of provocation — Whether evidence supported provocation and adequacy of jury directions; Sentencing — Death penalty — Mandatory death sentences unconstitutional; sentencing discretion required but death appropriate where conduct is particularly aggravated.
30 June 2010
Appellant lacked locus standi and failed to prove Estate ownership; respondents in possession entitled to succeed on trespass counterclaim.
  • Property law — possession and trespass — determination of superior possession as basis for title dispute; Company/contract law — interpretation of purchaser in Asset Sale and Purchase Agreement ("Mulli Brothers" v. alleged subsidiary) and effect on locus standi; Evidence — weight of administrative determinations (District Commissioner) and absence of title deeds; Counterclaim — trespass and damages sustained by occupants.
23 June 2010
Application for stay of execution dismissed; recognition of a validly elected Leader would not render the appeal nugatory.
  • Civil procedure — Stay of execution pending appeal — Preliminary procedural objections — Clean hands doctrine — Whether appeal rendered nugatory by recognition of a validly elected Leader of the Opposition under Standing Order 3(3).
10 June 2010
April 2010
The applicant’s request for a stay pending appeal was refused for lack of compelling reasons; High Court orders compel lawful reconsideration, not automatic licence renewal.
  • Civil procedure — Stay of execution — Exceptional relief requiring compelling reasons to prevent irreparable harm; Administrative law — Judicial review — Quashing of licence refusals for Wednesbury unreasonableness; Remedy — Orders requiring lawful reconsideration, not automatic licence renewals.
28 April 2010
Restriction and seizure under anti-corruption law may be justified to preserve assets, but authorities must prosecute promptly.
  • Corrupt Practices Act s.23 — Restriction notices and renewals; s.23A seizure orders; evidential burden on applicant to show lawful acquisition; protective purpose of restraint and seizure; constitutional protection against arbitrary deprivation; duty to prosecute expeditiously.
26 April 2010
A 13‑month delay in filing notice of appeal is inordinate; stay of execution cannot be granted absent a pending appeal.
  • Civil procedure — extension/enlargement of time to appeal — Order III rule 4 — must show good and substantial reasons and prima facie grounds; inordinate delay (13 months) fatal. Civil procedure — stay of execution — requires an appeal pending; stay improper where leave to appeal out of time has been refused
  • Property — bona fide purchaser and non‑dissipation — freezing/seizure unjustified
25 April 2010
January 2010
Risk of irrevocable loss of sole residence justified a stay of execution pending appeal due to special circumstances.
  • Civil procedure — Stay of execution pending appeal — Special circumstances required — Risk of appeal being rendered nugatory — Specific performance and mortgage over sole residence — Backdated/onerous mortgage terms — Inhibition order — Costs in the cause
19 January 2010
Unretracted caution statements and witness evidence sufficiently supported the jury's murder convictions; appeal dismissed.
  • Criminal law — murder — weight of evidence — jury verdict — unchallenged/retracted caution statements — accused's silence — appellate interference — sufficiency of evidence (Kafwambila principle).
13 January 2010
Minister’s abuse of office conviction for bypassing procurement procedures upheld; finding of personal gain set aside and sentences reduced.
  • Criminal law — Abuse of office (s.95 Penal Code) — Minister as public officer — Procurement procedures — Letter of intent treated as binding — No evidence of personal gain — Sentencing: maximum penalty excessive, reduction of sentence.
13 January 2010
December 2009
Death sentence upheld for premeditated, brutal murder; belief in witchcraft did not mitigate sentence.
  • Criminal law — Murder — Sentencing discretion — Death penalty reserved for cases with strong aggravating features — Premeditation and brutality — Belief in witchcraft not a mitigating factor — Sentencing is the judge’s duty, not the jury’s.
21 December 2009
November 2009
Court held overcrowded, poorly ventilated prisons violate prisoners' constitutional rights and ordered remedial measures.
  • Constitutional Law
    • — Prisoners' Rights — Cruel, Inhuman or Degrading Treatment — Overcrowding and Poor Ventilation
    • — Judicial Review — Justiciability, Proper Parties and Time Limits — Enforcement of Prisoners' Rights
    • — Prison Regulations — Enforceability of Statutory Minimum Standards Despite Resource Constraints
8 November 2009
September 2009
Whether s63(2) inquiry is required and appropriate compensation for early termination of a fixed-term employment contract.
  • Employment law — unfair dismissal — remedies — s63(2) Employment Act inquiry is to prioritise remedies — pleadings bind parties — s63(4) grants wide discretion to award just and equitable compensation, including possible damages for unexpired fixed-term contracts.
9 September 2009
July 2009
Appellate court may admit affidavit evidence; well-documented ownership claims prevail over inadequately supported matrimonial claims.
  • Matrimonial property distribution; appellate admission of affidavit evidence under Order 59(10)(2); evidentiary weight of documentary exhibits; parties’ intention and contribution; application of Malinki v Malinki and Chibweya.
21 July 2009
Court held trial court must not amend pleadings sua sponte to convert a wrongful dismissal claim into unfair dismissal.
  • Employment law — wrongful dismissal v. statutory unfair dismissal — common-law damages limited to notice pay — limits on court’s inherent power to amend pleadings sua sponte — duty of impartiality v. effective remedy.
20 July 2009
April 2009
A stay pending appeal requires clear evidence that judgment repayment is impossible; government financial strain alone is insufficient.
  • Civil procedure — Stay of execution pending appeal — Applicant must show good reason, typically a real prospect that judgment money will be irrecoverable — Bare assertions of debtor insolvency or governmental revenue shortfalls insufficient — Budgeted payments and loans do not, without evidence, justify depriving successful litigant of judgment funds.
30 April 2009
November 2008
Court held parties agreed only to grant use of the mining licence, not its transfer; plaintiffs' claim dismissed, counterclaim granted.
  • Mines and Minerals — mining licence: 'use' v transfer; contract interpretation — objective approach and surrounding background; agency — licence-holder may use agents (s.43); royalties — contractual obligation and counterclaim; plaintiffs failed to prove breach or loss.
3 November 2008
July 2008
Appeal allowed: custodial sentences for unlawful charcoal burning substituted with fines where no assessed damage and offenders not hardened.
  • Criminal Law
    • — Forestry offences — Destroying indigenous trees by making charcoal without licence — Sentencing discretion and proportionality
    • — Sentencing — Consideration of first‑offender status and absence of assessed damage value — Custodial sentence versus fine
13 July 2008
May 2008
Court held residence is not an absolute bar to inter‑country adoption; best interests and informed consent are paramount.
  • Family Law — Adoption — Inter‑country adoption and statutory residence requirement — Whether s 3(5) bars adoption by non‑residents; best interests of the child and CRC/ACHPR obligations
27 May 2008
Court allowed inter‑country adoption despite non‑residence, prioritising the infant's best interests and international obligations.
  • Family Law —  Adoption
    • — Inter‑country adoption — Whether residence requirement in s.3(5) is absolute or subordinate to the best interests of the child — Adoption of Children Act s.3(5)
    • — Child welfare principle — Paramountcy of the best interests of the child and requirement to interpret domestic law in conformity with CRC and ACHPR — Constitution ss.11,30,211
    • — Safeguards in inter‑country adoption — Informed consent, social welfare reports and last‑resort principle — Adoption of Children Act s.4
27 May 2008
April 2008
A stay will be refused unless the applicant proves the judgment debt would be irrecoverable; purchaser liable after sale.
  • Stay of execution — test for grant: good reason required; applicant must show judgment debt would be irrecoverable — courts avoid depriving successful litigant — sale as going concern transfers assets and liabilities — purchaser liable for judgment debt — refusal to stay pending appeal.
15 April 2008
December 2007
Government may excavate for irrigation on customary land; surface rights remain and compensation is payable for damage.
  • Land Law — Customary Land — Extent of Rights (Surface Use Only) — Land Act s26
  • Property/Development — Infrastructure on Customary Land — Authority To Excavate And Lay Pipes — Duty To Refill And Compensate
2 December 2007
October 2007
Whether 'wages' include allowances — court held they do and awarded recalculated compensation to the respondent.
  • Employment Law
    • — Wages and Remuneration — Whether 'wages', 'pay' and 'salary' include allowances and benefits — Construction of Employment Act s3
    • — Compensation for Unfair Dismissal — Calculation period for awards under s63(5) — Awards limited to years actually served
15 October 2007
July 2007
The mandatory death sentence for murder infringes dignity, fair trial and access to courts; section 210 is therefore invalid.
  • Constitutional law — Mandatory death penalty — Section 210 Penal Code — Violates right to human dignity and prohibition of inhuman or degrading punishment (s.19) — Denies access to court for final determination (s.41(2)) — Denies fair trial by preventing sentencing discretion (s.42(2)(f)) — Sentencing is part of trial — s.210 declared invalid to that extent.
19 July 2007
Fraudulent insurance claim justified summary dismissal; procedural irregularity did not make dismissal unfair.
  • Employment Law
    • — Discipline and Dismissal — Fraudulent submission of compensation claim as serious misconduct — Employment Act ss 57, 59, 61
    • — Procedural Fairness — Presence of employer’s representative during deliberations — Effect where evidence of misconduct is overwhelming
18 July 2007
June 2007
Court: constitutional provisions cannot be judicially invalidated; section 65(1) valid; independents unaffected; conduct governs ministerial cases.
  • Constitutional law — jurisdiction to invalidate constitutional provisions — anti‑defection (section 65(1)) — compatibility with rights to association, conscience, expression and political participation — independents unaffected — party‑elected MPs who resign and join another party cross the floor — ministerial appointment not per se defection.
14 June 2007
Courts cannot invalidate constitutional provisions; section 65(1) is valid, independents do not automatically cross the floor, ministerial appointment alone is not automatic crossing.
  • Constitutional Law — Judicial Review — Whether courts may invalidate provisions of the Constitution or only review laws and executive acts for conformity
14 June 2007
A confession can sustain a murder conviction if materially true and corroborated; confessions are not admissible against non-adopting co-accused.
  • Criminal law — Confession evidence — Confession admissible against co-accused only if adopted — Confession may sustain conviction if court satisfied beyond reasonable doubt of its material truth and supported by independent corroboration — Right to silence and effect of prior alibi statements.
14 June 2007
May 2007
Whether a photocopied certificate and formal charge defects can be cured and sustain conviction when prosecution proves falsity and mens rea.
  • Criminal law — Uttering false document; giving false information to public officer — Admissibility of secondary evidence (photocopy) under Rules 3(5) and 4 — CP&EC ss.3 and 5 cure formal defects — Right to silence and consequences — Appellate jurisdiction under s.11(3).
11 May 2007
February 2007
The National Assembly determines judges’ pay under s114; the Executive must implement that determination; courts will not probe internal parliamentary procedure.
  • Constitutional Law — Judicial Independence — Determination of judicial remuneration by National Assembly under s114(1) — Scope and effect of s114(2)
  • Parliamentary Privilege — Internal proceedings and Standing Orders — Non-justiciability of parliamentary procedure absent constitutional conflict
  • Public Finance — Budgetary provisions and Minister of Finance — Duty to implement valid National Assembly determinations
8 February 2007
January 2007
An employer’s request to stay and reconcile missing cash was reasonably justified and not false imprisonment; police detention was State responsibility.
  • Tort —  False imprisonment
    • — Employer’s instruction to remain at work to reconcile cash shortage — Reasonable justification
    • — Liability for police arrest and detention — Distinction between instigating arrest and merely providing information — Section 42(2)(b) (48‑hour rule)
4 January 2007
December 2006
Court dismisses bank's appeal, finding employee not party to fraud and dismissal unfair; damages upheld.
  • Employment law — unfair dismissal; factual findings on bank procedures and manager's duties final under s65 Labour Relations Act; absence of mens rea precludes dismissal for fraud; statutory awards (12 weeks, severance, s63(4) compensation) upheld.
19 December 2006
Refusal to renew a genuine fixed-term contract does not constitute unfair dismissal under the Employment Act.
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11 December 2006
October 2006
An insurer not party to proceedings cannot appear or be subrogated without first indemnifying the insured.
  • Civil Procedure
    • — Appeals from Registrar — Re‑hearing under Order 58 — Issues may be raised afresh on appeal
    • — Representation — Non‑party insurer’s right of audience — Insurance policy clause insufficient to confer right to appear; party status required
  • Insurance Law — Subrogation — Requirement of indemnity — Insurer not subrogated where it has not paid the insured
31 October 2006
May 2006
Section 71 permits sale by private treaty or auction; reserve-price approval required only for auctions, remedy for irregularity is damages.
  • Registered Land Act s.71 — construction of 'shall' and 'may'; permissive sale by private treaty or public auction; reserve price required only for auctions; duty to act in good faith; remedy for irregular exercise = damages (s.71(3)); injunctions ordinarily not available.
12 May 2006
November 2005
Murder suspects need not prove exceptional circumstances for pre‑trial bail; the State must show interests of justice.
  • Constitutional Law — Bail — Burden of proof under s.42(2)(e) — State must show that the interests of justice require detention
  • Criminal Procedure
    • — Murder suspects — Exceptional circumstances — Not required for pre‑conviction bail; applicable post‑conviction only
    • — Bail refusal — Requirement to state clear reasons — Lower courts must articulate grounds for refusal
15 November 2005
August 2005
31 August 2005
April 2005
Petitioner must prove electoral irregularities affected the result; use of an official vehicle and unsigned forms did not vitiate the election.
  • Electoral law — section 100 PPEA — timeliness of petition; no affidavit or prior MEC complaint required; Standard for nullifying elections — petitioner must prove irregularity affected result; Use of public/official resources — lawful use by incumbent Deputy Speaker post‑dissolution not proved to affect result; Verification of voters’ roll — insufficient evidence; Result-of-count forms and signatures — court should rely on primary evidence and not decide issues not pleaded.
11 April 2005
March 2005
Bank's revocation of irrevocable undertaking was grossly negligent; applicant awarded US$40,875 lost profits, costs halved.
  • Contract law — irrevocable letters of undertaking — bank liability — revocation as breach — gross negligence/wilful misconduct — limitation clause inoperative — damages for loss of profits.
29 March 2005
February 2005
Acceptance by conduct and payment of agreed sums extinguished further assessment and revived claims, including interest and costs.
  • Civil procedure — settlement by correspondence and conduct — acceptance by payment — whether out‑of‑court payment extinguishes further assessment of damages, interest and costs
15 February 2005
August 2004
Delay after an ex parte interim order and genuine disputes over title made mandatory interlocutory relief inappropriate.
  • Interlocutory injunctions — ex parte interim relief and subsequent delay — mandatory interlocutory injunctions exercised with caution — balance of convenience — competing title/regularization disputes — adequacy of damages.
23 August 2004
July 2004
12 July 2004
May 2004
An electoral commission abdicated its constitutional duty by referring misuse-of-public-resources complaints instead of investigating them, while an unpleaded ballot-paper order was quashed.
  • Constitutional and electoral law — electoral commission’s duty to investigate complaints — misuse of public resources — limits of originating summons — reliefs must be pleaded — court’s practical competence to order custody of ballot papers
17 May 2004
April 2004
An NGO lacked locus standi; courts require a 'sufficient interest' for public-interest judicial review.
  • Constitutional law; locus standi—'sufficient interest' test; judicial review (Order 53 r.3(7)); limits on public-interest/NGO standing; interpretation of s.46(2) vis-à-vis ss.15 and 41(3)
7 April 2004
January 2004
Customary land rights are constitutionally protected; eviction requires statutory expropriation procedures and compensation; injunction granted.
  • Customary land — constitutional protection of property rights — expropriation requires public utility, notice and compensation — Land Act and Land Acquisition Act procedural compliance — Environment Management Act grants locus standi to 'any person' — injunction to prevent environmental degradation
10 January 2004
December 2003
Disobedience of an injunction is civil contempt and does not disqualify an MP under s51(2)(c) absent a criminal conviction.
  • Contempt of court — civil contempt v criminal contempt — disobedience of injunction — qualification for Parliament under s51(2)(c) — moral turpitude and dishonesty — common law approach where no statutory contempt regime exists
22 December 2003