Bulawayo High Court - 2008

53 judgments
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53 judgments
Citation
Judgment date
December 2008
Applicant's delayed and unexplained inaction defeated urgent stay of eviction pending rescission; prospects of success and irreparable harm not shown.
Civil procedure — Urgent chamber application — Stay of execution pending rescission — Requirement of genuine urgency — Delay and lack of explanation fatal to urgency — Prospects of success and irreparable harm assessed — Eviction order and summary judgment.
10 December 2008
Urgent application dismissed for lack of urgency due to dilatory prosecution of the underlying claim.
Civil procedure – Urgent chamber application – urgency doctrine – delay and lack of diligence in prosecuting underlying claim defeats urgency – application dismissed (Kuvarega and authorities).
10 December 2008
November 2008
Disputed authenticity of signatures made motion proceedings inappropriate; matter converted to action and papers to stand as pleadings.
Civil procedure – motion proceedings – material dispute of fact as to authenticity of signatures – inappropriate to decide on affidavits – order that application stand as summons and papers stand as pleadings.
12 November 2008
Rescission granted where default resulted from counsel's illness and applicant showed a bona fide defence in a matrimonial dispute.
Civil procedure — Rescission of default judgment — Requirement to show no wilful default and a bona fide defence — Legal representative's illness as non-wilful cause — Matrimonial disputes warranting procedural flexibility.
12 November 2008
Former employees may not retain employer‑provided accommodation after dismissal pending damages claims; stay of execution refused.
Stay of execution – eviction – employer‑provided accommodation – termination of employment – outstanding damages do not entitle former employees to retain accommodation – procedural non‑compliance – costs on attorney and client scale.
12 November 2008
Applicant's substitution of buyers amounted to mutual cancellation; no contract existed on 1 February; provisional order discharged.
Urgent chamber application – contract for sale of vehicle – failure to pay by deadline – introduction of substitute purchasers – mutual cancellation of contract – no subsisting contractual right – provisional order discharged.
12 November 2008
The applicant improperly set the matter down without respondents' consent and failed to comply with Order 32.
Civil procedure — setting down opposed matters at short notice — consent of legal practitioners required — service by affixation — renunciation and assumption of agency — compliance with Order 32.
5 November 2008
Defendant’s claim that a third party possessed and sold the goods did not constitute a bona fide defence to plaintiff’s summary claim.
Contract – sale of goods – summary judgment – bona fide defence – defendant’s inability to deliver due to third party’s possession not a defence to direct contractual obligation – summary relief appropriate.
5 November 2008
A donkey is not "stock" under the Act; the mandatory nine-year minimum sentence for stock theft therefore does not apply.
Criminal law — Stock theft — Definition of "stock" excludes donkeys — Mandatory nine-year minimum sentence not applicable — Sentence varied on review.
5 November 2008
October 2008
A litigant cannot ordinarily set aside a valid default order solely because his lawyer gave wrong advice.
Civil procedure — Default order obtained through attorney negligence — Limits to relief for litigant’s attorney’s fault; condonation and setting-aside; responsibility for choice of legal representative; preservation of court rules and prevention of laxity.
22 October 2008
No new circumstances shown; bail refused due to counsel’s oversight, risk of abscondment and potential witness interference.
Bail — changed circumstances — omissions by counsel do not ordinarily constitute new facts; risk of abscondment; witness interference despite recorded statements; post-mortem authenticity challenge raised late.
22 October 2008
A single unauthorised sale of a firearm qualifies as dealing in firearms; conviction upheld, sentence set aside and replaced by a fine.
Firearms Act – unauthorised sale of firearm – whether single sale amounts to "engaging in trade or business" – guilty plea and adequacy of explanation to unrepresented accused – sentencing; amendment 22/2001.
22 October 2008
Court ordered sale and equal division of matrimonial property, rejecting claim that certain movables belonged to a third party.
Family law — Matrimonial property — Distribution on divorce — Recognition of homemaker's contribution — Declaration of disputed movables as matrimonial property — Sale and equal division to avoid unjust enrichment.
22 October 2008
Circumstantial proof and an unconfirmed statement failed to exclude reasonable hypotheses; accused acquitted.
Criminal law – Circumstantial evidence – Blom test – admissibility of warned and cautioned statements – voluntariness – post-mortem delay and transport damage – witness credibility – sketch plan/authentication – benefit of doubt.
14 October 2008
Court voided a foreign‑currency property sale but ordered local‑currency restitution to prevent unjust enrichment.
Illegal contract; foreign currency pricing; Exchange Control Regulations s(4)(1)(a)(ii); in pari delicto rule; restitution in local currency; unjust enrichment; nullity of sale agreement.
8 October 2008
Urgent stay of execution dismissed for lack of reasonable explanation for default and no bona fide defence.
Urgent application — stay of execution/rescission of default judgment — rescission requires reasonable explanation for default and bona fide defence with prima facie prospects — proof of service and title (registered owner) relevant.
8 October 2008
Agreement was an installment sale; seller’s cancellation invalid for failing to give statutory written 30‑day notice.
Contractual Penalties Act – installment sale of land – statutory definition (deposit plus two instalments and transfer on completion) – mandatory written notice and minimum 30‑day remedial period under s8 – invalid cancellation without compliance – specific performance/transfer ordered.
8 October 2008
Urgent chamber review was procedurally improper; applicant failed to follow prescribed review procedure and exhaust internal remedies.
Administrative/tribunal review – procedure – Order 33 rule 256 – review must be by court application directed to tribunal and parties; exhaustion of internal remedies required before court intervention; urgent chamber/ex parte review improper.
1 October 2008
July 2008
Court convicted both accused of murder under common purpose based on credible single eyewitness and corroborative evidence.
Criminal law – Murder – Doctrine of common purpose – Single eyewitness evidence – Constructive intent – Drunkenness and use of weapons.
28 July 2008
Applicants denied bail pending trial due to strong evidence and a real likelihood of absconding given assets and foreign connections.
Bail pending trial – presumption of innocence – likelihood to abscond – wealthy accused with foreign connections and valid passports – undercover operation strengthens State’s case – custodial discomfort as motive to abscond.
23 July 2008
Whether a purchaser may rely on an agent's apparent authority to sell the owner's property—appeal upheld with costs.
Property law – Agency and apparent/implied authority – Whether purchaser may rely on agent's representations – Exercise of discretion to condone procedural irregularity – Credibility findings
16 July 2008
HIV-positive status and widowhood alone do not justify bail pending appeal, particularly with a recent relevant previous conviction.
Criminal procedure — Bail pending appeal — HIV status not per se sufficient ground — Post-trial medical evidence — Widowhood as mitigating factor — Previous conviction militating against bail — No reasonable prospect of sentence alteration on appeal.
16 July 2008
June 2008
Court grants custody to the father where the mother abandoned the child and no evidence showed the father was unfit.
Family law – custody of minor – preference for natural parent’s custody absent evidence of unfitness – High Court as upper guardian intervenes where custody left with successive third parties.
25 June 2008
Long delay and misleading conduct defeated a claimant’s attempt to nullify probate and recover a house; punitive costs awarded.
Matrimonial property — delay/laches in enforcing proprietary settlement — verbal agreement to transfer immovable property — challenge to probate proceedings — misrepresentation to the Master — punitive costs (attorney-and-client).
11 June 2008
Whether the applicant's written, signed payment instructions were a bill of exchange, extending prescription from three to six years.
Prescription — whether claim arose from a bill of exchange — Bills of Exchange Act s3(1) — Prescription Act s15(c)(i) six-year period versus s15(d) three-year period — plea in bar/abatement — condonation of non-compliance with procedural rule (rule 138) under court's power (rule 4C).
11 June 2008
Convictions quashed due to unreliable, uncorroborated evidence and procedural unfairness; retrial ordered before a different magistrate.
Criminal review; aggravated indecent assault; reliability and corroboration of complainant’s evidence; medical/scientific proof of intoxicant effects; leading questions and unfair trial procedures; misdirection on onus of proof; unlawful detention—absence of proven restraint.
11 June 2008
Bail pending appeal granted where sentence appears excessive and accused unlikely to abscond, subject to strict conditions.
Criminal law – Bail pending appeal – considerations: prospects of success on appeal and risk of absconding – aggravated indecent assault – apparent excessive sentence – bail granted with stringent conditions (cash deposit, residence restriction, exclusion from complainant’s home).
11 June 2008
Appellate court upheld separate sentencing for multiple exchange control offences, finding no misdirection or excessive fines.
Exchange Control offences – sentencing – globular versus separate sentences – mitigation (guilty plea, cooperation, commercial motive) – dollar-for-dollar fines – appellate interference standard (disturbingly inappropriate).
4 June 2008
May 2008
An agent cannot claim commission when the selling mandate expired or was validly cancelled before the purchaser's offer.
Estate agent commission — validity, expiry and cancellation of mandate — seven days' notice — timing of purchaser's offer — exclusive mandate not granted — summary judgment inappropriate where bona fide defence exists.
28 May 2008
Accused’s actions amounted to attempted rape; the fine and suspended sentence were inadequate, so the review certificate was withheld.
Criminal law – indecent assault v attempted rape – use of violence and attempted removal of clothing – sentencing inadequacy – custodial sentence of 5–8 years appropriate – review: certificate withheld.
28 May 2008
Application for absolution denied; company-held business assets may be part of the matrimonial estate and require full hearing.
Divorce — Ancillary relief — Absolution from the instance — Test for absolution (Supreme Service Station) — Not for piecemeal determination of issues; Business assets/company-held assets — net worth may form part of matrimonial estate.
21 May 2008
Applicant's defiance of prior court orders amounted to 'dirty hands', barring equitable relief; application dismissed with costs.
Civil procedure — Clean hands doctrine — Non-compliance with prior court orders — Applicant in open defiance disentitled to equitable relief; interim interdict and stay refused on that basis.
21 May 2008
Ex parte freezing order discharged where applicant withheld material facts and was a willing participant in a potentially illegal exchange transaction.
Civil procedure – Ex parte provisional order – Duty of full and frank disclosure – Material non-disclosure and misleading affidavits – Transactions tainted by possible Exchange Control contraventions – Discharge of provisional order with costs.
21 May 2008
Whether circumstantial evidence and an admitted affidavit proved the respondent’s adultery and justified damages and enhanced costs.
Delict/damages – adultery – proof by circumstantial evidence – admissibility of affidavit under s27 Civil Evidence Act – assessment of witness credibility – award of damages and attorney-and-client costs.
21 May 2008
Urgent interdict dismissed for self-created urgency and lack of locus standi over a vehicle registered to a third party.
Urgent application — self-created urgency and inadequate certificate; locus standi — third-party registered owner not cited or supporting affidavit; provisional interdict over movable property; mechanic's improvement lien asserted.
14 May 2008
Principal’s conduct and signed special power created ostensible authority, validating agent’s sale despite defective powers.
Agency — apparent/ostensible authority — defective general/special power of attorney — principal’s conduct creating estoppel — representation to third parties — transfer of immovable property.
14 May 2008
Condonation refused for nearly four-year delay due to inadequate explanation, lack of bona fides and credible service.
Civil procedure – condonation for late rescission – inordinate delay and inadequate explanation – bona fides – personal service – false explanations – costs on attorney-client scale
14 May 2008
Incomplete trial record and unrecorded recusal application required setting aside dismissal and ordering a fresh hearing.
Civil procedure — Record of proceedings — Adequacy and duty to record rulings, objections and hearings — Recusal — Appearance of bias — Referral for rehearing when record is incomplete.
14 May 2008
Sale subject to Master’s approval and based on a void executor’s appointment is unenforceable; provisional order discharged.
Administration of Estates Act s120 — condition precedent to sale — suspensive condition — inchoate contract; validity of executor's appointment — will declared invalid, appointment set aside — transfer requires valid executor authority; provisional order discharged.
14 May 2008
Pre‑plea challenges must test whether a charge discloses an offence; unsworn complainant statements cannot decide merits prematurely.
Criminal procedure — Pre‑plea challenge to charge (s178/s171) — Court must assess whether charge discloses an offence and gives sufficient particulars, not adjudicate merits — Unsigned/unsworn complainant statements inadmissible at pre‑plea stage — Prima facie sufficiency of state outline; no mala fides shown.
14 May 2008
Convictions for possession of suspected stolen goods cannot be based on guilty pleas without evidence of the finder’s reasonable suspicion.
Criminal law – Possession of goods reasonably suspected to be stolen (s 12(2) Miscellaneous Offences Act/s 125 Criminal Law (Codification and Reform) Act) – Plea proceedings (s 271(2)(b) CPEA) – Requirement that finder’s reasonable suspicion be proved by evidence – accused cannot admit another’s state of mind – convictions entered on plea without such evidence unlawful – convictions quashed and matters remitted for trial de novo.
14 May 2008
Whether appellants knowingly used forged travel documents and whether sentencing relied on a repealed mandatory imprisonment provision.
Criminal law – Forgery/use of forged travel documents – Knowledge and procurement of forged documents – Sentencing law – Mandatory custodial provision repealed; sentencing discretion and mitigation (pregnancy, parental responsibilities, first offender principle).
14 May 2008
Whether a forfeiture order added after sentencing is valid and whether fresh sentencing is required following that irregularity.
Criminal procedure – Gold Trade Act s8(1) – possession of unregistered gold – alleged post-sentencing insertion of forfeiture order into court record – irregularity in Criminal Record Book entries – High Court review powers – confirmation of conviction and remission for fresh sentencing on forfeiture.
14 May 2008
Juristic persons cannot be imprisoned; alternative custodial terms deleted, fines retained; convictions confirmed.
Criminal law – Sentencing juristic persons – Corporations/entities cannot be sentenced to imprisonment; only fines permissible – Alternative custodial terms deleted – Exception where natural person charged under s277(5) Criminal Law (Codification and Reform) Act or s385 Criminal Procedure and Evidence Act.
14 May 2008
Applicant failed to justify piercing the corporate veil; share sale did not affect tenant’s lease or option.
Company law – lifting or piercing corporate veil – requirement of fraud or manifest injustice; Sale of shares versus sale/transfer of immovable property – effect on tenant’s lease and contractual option; Provisional order discharged; Costs on attorney-client scale.
14 May 2008
Enforceability of a lease clause allowing immediate cancellation for rent default and consequent eviction of the respondent.
Commercial lease – Clause permitting immediate cancellation for rent default – Validity and enforceability – Non‑applicability of Contractual Penalties Act and Commercial Premises (Lease Control) Act/Regulations – Tender after cancellation does not reinstate lease – Eviction and costs.
13 May 2008
President obliged to publish Gazette notice and order a by-election within 14 days after CEO's declaration of a candidate's death.
Electoral law – Death of candidate (s50) – Chief Elections Officer's declaration need not be written – President's mandatory duty to publish Gazette notice ordering by-election within 14 days (s39(2)) – Peremptory vs directory statutory language – Lack of funds/public inconvenience not established by affidavit – Nomination court and by-election timetable.
8 May 2008
March 2008
Conviction for unlicensed driving quashed where learner's licence conditions and material facts were never determined.
Road Traffic Act — Learner's licence conditions (s9) — Correct charge under s9(10) not s6(1)(a); failure to determine licence class, passengers, and "L" plates; procedural irregularity; conviction quashed; retrial de novo.
26 March 2008
Accused convicted of murder with constructive intent for a joint, lethal assault on a handcuffed victim; self-defence and intoxication rejected.
Criminal law – Murder – Constructive intent – Common purpose where co-assailants jointly assault a handcuffed victim – Self-defence rejected where victim posed no threat – Intoxication not exculpatory; reliance on post-mortem despite non-production of weapons.
21 March 2008
Failure to consider community service before imprisoning for 24 months or less is a reviewable sentencing misdirection.
Criminal procedure - Sentencing - Obligation to consider community service as an alternative to imprisonment for sentences of 24 months or less - Failure to consider constituting misdirection on review - Custodial sentence as last resort.
13 March 2008