Malawi Supreme Court of Appeal

378 judgments
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Results. 378 judgments found.

378 judgments
October 2003
Ex parte injunctions require full, frank disclosure; misrepresentation disentitles applicant to stay of discharge.
  • Civil procedure — Ex parte injunctions — Duty of full and frank disclosure — Misrepresentation of alternative accommodation — Stay of discharge governed by ex parte principles, not Marriage Act or Married Women’s Property Act.
7 October 2003
August 2003
Whether a government bureau lacking legal personality can be sued and the correct procedure to challenge restriction notices.
  • Constitutional/administrative law — statutory bodies — legal personality — Anti‑Corruption Bureau lacks capacity to sue or be sued; suits should be against Attorney General or Director; procedure under s.23(5)-(6) — Notice of Motion appropriate; natural justice — notice given; costs against non‑suable body untenable.
20 August 2003
April 2003
Speaker is not the proper defendant in judicial review of parliamentary acts; Attorney General is, and injunctions against Government are prohibited.
  • Administrative law — Judicial review of parliamentary decision — Speaker not proper party; Attorney General proper respondent — Civil Procedure (Suits by or against Government) Act requires notice and bars injunctions against Government — procedural defect of wrong party may defeat interlocutory relief — right to review Parliamentary compliance with natural justice
27 April 2003
Seizure and freezing orders under CPA s32(5) are civil preservatory measures; ex parte relief is permissible with later inter partes safeguards.
  • Corrupt Practices Act s32(5) — seizure and freezing orders; civil ex parte applications; duty of full and frank disclosure; preservation of assets pending trial; property rights and constitutional limitation; tracing/segregation of assets; unclean hands; no statutory receivership under CPA.
16 April 2003
March 2003
Appellant's murder conviction quashed where prosecution failed to prove malice aforethought or participation in the fatal mob attack.
  • Criminal law — Murder — Malice aforethought — Requirement to prove intention to kill or cause grievous harm; Criminal law — Joint enterprise — Liability where accused participated in common purpose; Evidence — Dying declaration — Reliability examined against postmortem findings; Criminal procedure — Jury directions — Provocation and self‑defence not necessary on these facts; Conviction quashed for insufficient evidence
6 March 2003
December 2002
Trial judge erred on burden of proof and evidence; appellant's dismissal of the manager for misconduct was justified.
  • Employment law — summary dismissal — misconduct and negligence (unauthorised debits, failure to obtain insurance policies, irregular lending); burden and standard of proof in civil claims; admissibility and weight of bank records; impermissibility of judicial reliance on personal knowledge; defamation — truth defence
17 December 2002
November 2002
Appellant entitled to market-value damages for conversion; loss-of-profits claim rejected for lack of pleading and proof.
  • Conversion — measure of damages: market value at time of conversion; consequential loss
  • Loss of use — general damages, modest; cannot substitute for loss of profits without pleading and proof
  • Special damages — must be specifically pleaded and strictly proved
  • Procedural delay — inordinate delay between hearing and judgment criticised
10 November 2002
September 2002
Claims for pre-Constitution abuse of power must be brought to the National Compensation Tribunal, not the High Court.
  • Constitutional law — section 138(1) National Compensation Tribunal exclusive original jurisdiction for pre-Constitution abuses of power; section 108(1) limited; section 138(3) power to remit; malicious prosecution and false imprisonment claims
19 September 2002
Whether the appellant held valid title after the government determined the respondent’s lease and whether the respondent’s re-entry was trespass.
  • Property law — Lease determination for breach of development covenant — Validity of subsequent grant of lease — Title — Trespass for re-entry after determination — Trial de novo and non-binding earlier rulings — Damages for trespass and pleading particularity
16 September 2002
May 2002
A stay was ordered where the subcontract's arbitration clause was incorporated and accepted by conduct, requiring arbitration.
  • Arbitration Act s.6(1) — application to stay proceedings; incorporation of subcontract general conditions by annexes and conduct; implied acceptance of terms; inapplicability of third-party contract clause; referral to arbitration in Mendoza under Clause 36
28 May 2002
March 2002
Consent stay discharged where appellants failed to comply with time condition to prepare appeal record and skeletal arguments.
  • Civil procedure — consent order — stay of execution conditional on record and skeletal arguments being ready by fixed date — failure to comply with temporal condition — consent order discharged — duty of appellant to prepare record and seek extension if necessary
11 March 2002
A late, vague request for company minute books was rightly refused as unnecessary, a fishing expedition, and a delaying tactic.
  • Civil procedure — production and inspection of company minute books — necessity and timing of application — O.24 r.13(1) discovery rules — best evidence — fishing expedition — trial judge’s discretion — limited appellate interference
7 March 2002
November 2001
Unattested draft will cannot determine executor choice; court may appoint neutral trust corporation under s.42 for proper estate administration.
  • Wills — unattested draft not a will; Administration of estates — s.42 Wills and Inheritance Act — court may appoint administrator other than ordinarily entitled person; appointment of trust corporation where parties mistrustful; costs — each party pays own costs
12 November 2001
October 2001
Stay granted pending appeal after High Court misapplied American Cyanamid principles and considered irrelevant factors.
  • Interlocutory injunctions — American Cyanamid principles — good arguable case, serious question, balance of convenience — stay of execution pending appeal — prohibition on deciding contentious issues on affidavits — irrelevant considerations (judiciary/legislature conflict) — irreparable harm — costs in the cause.
31 October 2001
A stay was granted pending appeal after the High Court misapplied Cyanamid principles and failed to exercise proper discretion.
  • Civil procedure — Stay of execution pending appeal — Interlocutory injunction — American Cyanamid principles — Balance of convenience vs 'balance of justice' — Court must not decide claims on affidavits — Improper consideration of irrelevant factors — Failure to exercise judicial discretion
30 October 2001
Whether retracted confessions and circumstantial evidence could sustain convictions and whether a confession can be used against co-accused without adoption.
  • Criminal law — s.176 CP&EC — retracted confessions admissible but only weightable if tribunal satisfied beyond reasonable doubt of material truth; need for external pointers/corroboration; confessions against co-accused inadmissible unless adopted by that co-accused; sufficiency of circumstantial evidence and duty of judge to direct jury
17 October 2001
September 2001
An in‑court agreement based on alleged witchcraft and to stay sentence is illegal and unenforceable; committal and restitution ordered.
  • Witchcraft Act s6 and s9 — representation as a wizard/witch and use of charms — illegality of contracts founded on witchcraft; Public policy — agreements to discontinue criminal proceedings or stay execution of sentence in court proceedings — Magistrate functus officio and lack of power to stay execution; Restitution under Criminal Procedure and Evidence Code s148(1); Seizure and sale of assets to satisfy restitution
23 September 2001
August 2001
Special damages require strict proof on the balance of probabilities; credible oral evidence may suffice; business-loss must be supported by contemporaneous evidence.
  • Damages — Special damages must be specifically pleaded and proved strictly (on balance of probabilities); absence of receipts not fatal if oral evidence credible; General damages — loss of business must be supported by contemporaneous evidence; Appeal — fresh evidence on appeal limited; operational cost projections admissible if supported and unchallenged
22 August 2001
July 2001
Appeal dismissed: appointment complied with customary law and Chiefs Act; appellants’ delay and acquiescence precluded relief.
  • Chieftaincy succession — Chiefs Act s4(2) entitlement and majority support — customary nomination procedures (women and nkhoswe) — delay/acquiescence — removal inquiries under s11(2)/s12 — judicial reluctance to disturb long-accepted installations
10 July 2001
June 2001
Quorum absence invalidated expulsion; administrative tribunal may re-hear after procedural-review quashing; "unless" limb set aside.
  • Administrative law — judicial review — procedural irregularity for lack of quorum — quorum requirement under university rules — doctrine of necessity inapplicable where no quorum at outset — power to re-hear after quashing — contempt and compliance with reinstatement orders
3 June 2001
October 2000
Section 80(2) requires a majority of votes cast, not a majority of all registered voters, to elect the President.
  • Constitutional interpretation — Election law — Meaning of "majority of the electorate" in s80(2) — Majority of votes cast, not of all registered voters — PPE Act s96(5) consistent with Constitution — Limited weight to legislative history
22 October 2000
August 2000
Appeal allowed: respondents failed to prove false imprisonment or slander; aggravated damages require specific pleading.
  • Tort — False imprisonment: liability where defendant or agent makes a charge procuring police arrest; distinction between laying information and making a charge; burden of proof on claimant
  • Defamation — necessity of proving the words as pleaded
  • Damages — special and aggravated damages must be specifically pleaded with particulars
24 August 2000
Insufficient Turnbull warning was outweighed by fingerprint and caution-statement corroboration, so conviction was upheld.
  • Criminal law — Visual identification — Dock identification — Turnbull warning required; Fingerprint evidence as corroboration; Caution statement; Safety of verdict; Missing exhibits explained
14 August 2000
April 2000
Registration of a UK arbitration award upheld because arbitrators validly had jurisdiction under a concluded contract.
  • Arbitration — Registration of foreign arbitration awards — British and Commonwealth Judgments Act — Enforcement under Arbitration Act (ss.27, 37, 38) — Jurisdiction of arbitrators — Existence of contract determined by documentary evidence
16 April 2000
Procedural defects in treating a witness as hostile and some misdirection on caution statements were noted, but conviction upheld on credible eyewitness evidence.
  • Criminal procedure — hostile witness application — necessity of laying foundation and showing prior statement; Criminal evidence — caution/confession statements — exculpatory statements not evidence of asserted facts but admissible as evidence of making and reaction; Corroboration — no general requirement where single credible eyewitness evidence suffices; Appeal — review of jury verdicts
16 April 2000
November 1999
Where a claim pleads an unspecified "bank rate" for interest, the court will apply the Judgment Act rate (5%).
  • Interest — rate to apply where claim pleaded as "bank rate" without specification — commercial versus investment rates — pleading requirements for interest — application of Judgment Act rate (Courts Act s.65) as convenient guide
23 November 1999
August 1999
An interlocutory injunction preventing the appellant from remaining in the matrimonial home was justified by threats of violence.
  • Interlocutory injunction — matrimonial home — alleged domestic violence and threats — adequacy of damages — injunction duration tied to pending divorce proceedings — equity looks to substance not form — American Cyanamid principles applied.
26 August 1999
July 1999
Applicant's challenge that key prosecution witnesses were "tainted" and that the summing‑up was inadequate was rejected.
  • Criminal law — murder — credibility of eye‑witnesses — alleged "tainted" witnesses — adequacy of summing‑up and directions to jury — appellate review of jury verdict
27 July 1999
February 1999
Bail for serious offences is discretionary; prosecution non-objection is not decisive and prolonged remand alone is not exceptional.
  • Criminal law — Bail — Constitutional right to bail not absolute — Serious offences (murder) require exceptional circumstances for bail — Prosecution's non-objection not dispositive — Committal to High Court a legitimate factor — Subsequent bail applications require material change.
24 February 1999
24 February 1999
No binding sale existed; appellant awarded repayment of the redemption sum with 5% statutory interest, specific performance denied.
  • Contract law — agreement to agree; no binding sale where essential term (price) not agreed — Specific performance refused — equitable clean hands — restitution of redemption payment — statutory interest under s.65 Courts Act — contractual interest must be pleaded
22 February 1999
November 1998
Pensionable status does not, without clear wording or pleading, preclude termination on contractual notice; appeal allowed and pension benefits awarded with interest.
  • Employment law — implication of terms — pensionable or "permanent" employment does not, without clear language, prevent termination by notice; pleadings required for implied terms — tort claims not to supplant contractual claims
10 November 1998
August 1998
Court ordered return of employer-supplied materials, holding contractor’s lien invalid absent architect’s interim certificate.
  • Interlocutory mandatory injunctions — balance of convenience and conduct of parties; building contract lien — dependence on architect’s interim certificate (Clause 31); quantity surveyor valuations not substitute for architect’s certificate
10 August 1998
April 1998
Alleged partnership failed; truck treated as estate property and divided fairly between dependant and excluded child.
  • Wills and Inheritance Act ss.16(2)(b) and 17 — intestate succession — dependants' protection and fair distribution — alleged partnership not substantiated — estate property versus partnership property — remedy by transfer with compensation or sale and equal division.
9 April 1998
July 1997
Whether jury directions on conspiracy, admissibility of hearsay, and the accused's constitutional right to silence were correctly applied.
  • Criminal law — Conspiracy: knowledge required for late joiners; Criminal procedure — Right to remain silent — sections 313 and 314 invalid to extent inconsistent with Constitution; Evidence — hearsay and statements by deceased; Trial procedure — fairness of judicial summing-up; Costs — State ordered to pay appeal costs where prosecution abandons appeal
30 July 1997
September 1996
Payment in lieu of notice is "remuneration"; a clause allowing one month's pay for three months' notice violated the constitutional right to fair remuneration.
  • Constitutional law — Right to fair and safe labour practices and fair remuneration — Payment in lieu of notice constitutes remuneration — Contractual term permitting one month's pay in lieu of three months' notice inconsistent with constitution — Reciprocal clause insufficient where imbalance of bargaining power
2 September 1996
November 1995
The respondents cannot sue the President or Speaker personally for official acts; proceedings must be brought via the Attorney General.
  • Constitutional law — Suit against high office‑holders — President and Speaker not "public officers" for personal suability — Actions against official acts to be brought via Attorney General — Presidential immunity under s.91(1) — Parliamentary privilege under s.60 — Declaratory relief requires sufficient interest/standing
19 November 1995
September 1995
Severance, trial delay and the prosecution's burden under s.42 justified granting bail to the appellants.
  • Constitutional right to bail (s.42) — "interests of justice" as qualification — prosecution's burden on bail — severance of charges as fresh basis for bail — caution in relying on s.293 statements — delay and length of trial as grounds for bail
10 September 1995
Bail is a constitutional right unless the prosecution shows, on balance, that the interests of justice require continued detention.
  • Constitutional right to bail (s.42) — "interests of justice" test — burden on prosecution to show detention justified — "exceptional circumstances" not always prerequisite — severance of charges may justify fresh bail application — limited weight of s.293 statements at bail stage — delay and length of trial relevant
10 September 1995
August 1995
20 August 1995
April 1994
Whether the appellant was an employee and entitled to damages for injury caused by the employer's failure to provide safe equipment.
  • Employment law — employee v independent contractor — control, integration and economic reality tests; Employer's duty to provide safe equipment and workplace; Causation — missing guard and defective grinding disc; Rejection of assumption of risk defence; Quantum for permanent disablement.
15 April 1994
March 1993
Sedition convictions upheld on statutory construction; incitement to violence not universally required, but sentences reduced as excessive.
  • Criminal law — Sedition — Interpretation of s.50(1) Penal Code — Definitions disjunctive — "Hatred, contempt, disaffection" ordinary meaning — Incitement to violence not necessary except possibly under s.50(1)(b); Constitutional law — Freedom of expression subject to reasonable restrictions; International instruments — UDHR part of domestic law, African Charter not enforceable absent incorporation; Sentence — appellate reduction for manifest excessiveness
28 March 1993
December 1992
The Supreme Court of Appeal has no jurisdiction to review its own delivered judgment except under the narrow "slip rule" or pre-perfection practice.
  • Civil procedure — Judicial review — Whether a Court of Appeal may review its own judgment — Order 53(3) excludes Court of Appeal — slip rule and Rule 29 (practice of Court of Appeal in England) — powers of review are statutory.
11 December 1992
August 1992
Court granted stay of execution pending appeal due to special circumstances despite likelihood respondent could repay damages.
  • Civil procedure — Stay of execution pending appeal — Discretionary relief — Balance between protecting successful litigant's judgment and preserving right to appeal — Special circumstances and probability of inability to repay as factors — Large awards representing future pension benefits.
18 August 1992
Court granted stay pending appeal due to special circumstances despite respondent's apparent ability to repay; costs awarded to respondent.
  • Civil procedure — Stay of execution pending appeal — Court's discretion; special circumstances; successful litigant's ability to repay not decisive; large future pension award considered.
15 August 1992
April 1992
Whether a towing contractor was solely negligent in a recovery tow and proper measure of damages where insurance paid.
  • Tort—Negligence—Towing and recovery operations; contributory negligence; assessment of damages where insurance proceeds available; proof of funeral and loss-of-use damages; costs on successful appeal.
18 April 1992
March 1992
Illegality of credit fuel sales defeated respondents’ claim, but appellant denied costs due to partial success.
  • Contract law — Illegality; Conservation of Motor Fuel Regulations — sale of fuel on credit; sub-contracting and L.P.O. transactions; evidentiary burden on set-off/deductions; costs discretion where success is partial.
20 March 1992
February 1992
Application for directions on repayment of monies recovered under a set‑aside judgment dismissed as an abuse of court process.
  • Civil procedure — Abuse of process; effect of appellate setting aside of trial judgment on monies recovered; restitution of sums recovered pursuant to an annulled judgment; interaction with Registrar's orders and stays.
10 February 1992
November 1989
23 November 1989
Whether an application to amend pleadings, accounting particulars and documentary evidence affected the bank’s counterclaim and liability.
  • Civil procedure — amendment of pleadings — leave to amend after evidence — objections during trial; Banking accounts — counterclaim accounting — effect of further and better particulars and ledger errors; Pleadings — joint versus several liability; Evidence — admissibility and weight of appellant’s cash book (exhibit); Costs — apportionment where appeal partly succeeds.
6 November 1989