Constitutional Court of Zimbabwe

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151 judgments
Citation
Judgment date
March 2021
Speaker's disciplinary action was not conduct attributable to Parliament under section 167(2)(d), so special jurisdiction was not triggered.
Constitutional jurisdiction s167(2)(d) — attribution of Speaker's acts to Parliament — Standing Orders confer independent disciplinary powers — requirement to identify specific constitutional obligation and impugned conduct.
29 March 2021
February 2021
Whether Parliament may obtain an extension to comply with a re-vote order amid COVID-19 and s147 lapse concerns.
Constitutional procedure — Constitutional Court jurisdiction and finality of its orders — Locus standi of parliamentary authorities to seek ancillary relief — Section 147 (lapsing of business on dissolution) — COVID-19 lockdown as ground for extension of time to comply — Section 328 voting requirements for constitutional amendment.
25 February 2021
Failure to file the mandatory r67 written statement and to serve the judge and Prosecutor‑General rendered the bail appeal fatally defective.
Criminal procedure — s 121(1)(b) — appeals against refusal to vary bail conditions — r 67 Supreme Court Rules — written statement mandatory; notice of appeal insufficient; service on Prosecutor‑General and judge required; non‑compliance fatal; r 4 discretion declined.
3 February 2021
December 2020
Compulsory school pledge requiring flag salute and “Almighty God” violated pupils’ and a parent’s constitutional religious rights.
Freedom of religion – compulsory school pledge – mandatory flag salute and religious wording – s 60(1) – conscientious belief test; Parental rights – s 60(3) – right to determine moral and religious upbringing; Limitations – s 86(2) – must be in terms of a law of general application; Preamble – ceremonial only, cannot justify rights limitation; State neutrality and protection of religious pluralism; Children’s vulnerability and evolving capacities.
28 December 2020
November 2020
Constitutional Court declined jurisdiction over employer’s failure to remit union dues, directing labour remedies under the Labour Act.
Labour law – union dues – Collection and remittance under Labour Act ss 52 and 54 – Constitutional jurisdiction – avoidance and subsidiarity – standing of trade union under s 85(1) and s 45(2) of the Constitution.
18 November 2020
September 2020
23 September 2020
23 September 2020
July 2020
Direct access denied: disagreement over factual findings and obiter remarks do not raise a constitutional fair-trial issue.
Constitutional Court—direct access exceptional—requirements under r 21(3) and s 85(1)(a); evaluation of evidence by subordinate courts not normally a constitutional issue; s 170(2) reverse onus—obiter reference; abandoned grounds of appeal cannot be revived; disguised appeal dismissed.
2 July 2020
No constitutional issue arose; leave to appeal refused because the Supreme Court’s non-constitutional findings are final.
Constitutional jurisdiction – leave to appeal – r 32(2) and s 167(5)(b) – limits of Constitutional Court’s jurisdiction; Evidence – admissibility of call records – consent negates constitutional challenge; Fair trial and presumption of innocence – factual/evidential disputes not automatically constitutional; Finality – Supreme Court decisions on non-constitutional matters are final and not appealable to Constitutional Court.
2 July 2020
March 2020
Court held Senate vote invalid for falling one vote short of two-thirds of constitutional membership; National Assembly vote upheld.
Constitutional law — Amendment of Constitution — s 328(5) two‑thirds threshold — "membership of each House" means total constitutional membership — calculation under s 344(3); Administrative law — Justiciability — Parliament amenable to suit in its name; Parliamentary procedure — Hansard, Journal and audio recordings as evidentiary record; Remedy — declaration of invalidity suspended and direction to re-vote.
31 March 2020
January 2020
Direct access refused where applicant failed to show interests of justice; inquest and trial complaints were non-constitutional or remediable on appeal.
Constitutional procedure – direct access – requirements of r 21(3) – interests of justice – s 85(1) allegation suffices to institute matter; Criminal procedure – inquests – fairness of trial – fair-trial rights accrue on charge; Administrative law – s 68 and Administrative Justice Act – statutory remedy must be pursued; Finality of appeals – Supreme Court decisions on non-constitutional matters are final.
8 January 2020
Direct access refused where constitutional challenge to s 8(6) was premature and not necessary for resolution of pending criminal proceedings.
Constitutional procedure — Direct access — Exceptional remedy; referrals under s 175(4) — frivolous or vexatious test — s 8(6) Money Laundering Act — evidential burden vs definition of crime — prematurity of abstract constitutional challenge.
8 January 2020
July 2019
Confirmation of the High Court’s invalidation of s 93(5A) denied because the applicant lacked standing and the declaration would have no practical effect.
Constitutional law — confirmation of lower-court declaration of invalidity — locus and practical effect — statutory interpretation of s 93(5A) Labour Act — standing and requirement to show injury by impugned provision.
3 July 2019
April 2019
Judicial corporal punishment of male juveniles violates the constitutional prohibition on cruel, inhuman or degrading treatment and is struck down.
Constitutional law — prohibition of torture, cruel, inhuman or degrading punishment — judicial corporal punishment of male juveniles — human dignity — section 53 — confirmation of invalidity — CRC/ICCPR jurisprudence — juvenile justice principles; alternatives to corporal punishment.
3 April 2019
March 2019
A Constitutional Court will not entertain direct review of a Supreme Court non‑constitutional decision based on mere alleged wrongness; interests of justice required.
Constitutional law – direct access under s85(1) – scope and limits – interests of justice and r21(3)/(8) – finality of Supreme Court decisions on non‑constitutional matters – stare decisis – equality/equal protection (s56) – wrongness of decision does not equal constitutional breach.
13 March 2019
Direct access refused: merits determination by subordinate court precludes s175(4) referral complaint; appeal is the appropriate remedy.
Constitutional procedure – s 175(4) referral of constitutional questions – distinction between refusal to refer and merits determination; Direct access – s 85(1) – subsidiarity and appeal as proper remedy; Prosecutorial authority – CP&E Act s 5(2) permits Prosecutor-General to appoint any legal practitioner; Equal protection – s 56(1) – not engaged where subordinate court decided merits.
6 March 2019
February 2019
27 February 2019
Application dismissed for lack of constitutional issue and failure to comply with rules requiring identification of a constitutional matter.
Constitutional jurisdiction – right of appeal to Constitutional Court – appeal lies only where a constitutional matter was raised and decided below – Rules 32(2) and 32(3)(c) – procedural compliance required for leave to appeal – non-constitutional Supreme Court decision not appealable to Constitutional Court.
27 February 2019
Leave to appeal denied where no subordinate court decision on a constitutional matter existed due to the applicant's withdrawal.
Constitutional jurisdiction; leave to appeal r 32(2)-(3); requirement of subordinate court decision on constitutional matter; withdrawal of proceedings not a court decision; no appeal against withdrawal.
27 February 2019
Leave to appeal dismissed: no constitutional issue was decided by the Supreme Court, so no appeal to the Constitutional Court lies.
Constitutional jurisdiction – right of appeal to Constitutional Court – appeal lies only where Supreme Court determined a constitutional issue – subordinate court labour disputes as non-constitutional matters – r 32(3)(c) requirement to identify constitutional matter – s 169(1) and s 167(5) implications.
27 February 2019
Employment of serving security-service members as prosecutors breaches s208(4); NPA must disengage them within twenty-four months.
Constitutional law – separation of security services and civilian institutions – s208(4) – definition of "civilian" – National Prosecuting Authority a civilian institution – employment of serving security officers as prosecutors unconstitutional absent public emergency – suspension of invalidity to avoid disruption.
19 February 2019
Referral under s175(4) must arise from established facts; improper referral without opposing affidavit was struck off the roll.
Constitutional law – s 175(4) referral – referral must arise from facts before referring court – magistrate must consider merits and make factual findings – Magistrates' Court Rules require opposing affidavit when denying facts in application – occupation of gazetted land requires lawful authority (offer letter/permit/land settlement lease) – eviction proceedings – referral frivolous/vexatious – matter struck off roll.
18 February 2019
November 2018
Section 85(1) permits constitutional challenges to Supreme Court decisions only where the court’s unlawful conduct disabled lawful adjudication; mere disagreement is insufficient.
Constitutional review of judicial decisions – s85(1) individual constitutional complaints – direct access (r21) – finality of Supreme Court decisions (s169(1), s26) – disguised appeal – requirement to show failure to act in terms of law disabling lawful decision-making.
20 November 2018
October 2018
Court affirmed constitutional duties of public participation and PLC scrutiny, upheld gazetting/PLC compliance, and referred contested Harare hearing facts to High Court.
Constitutional law – exclusive jurisdiction of Constitutional Court under s 167(2)(d) – parliamentary obligations to facilitate public participation (s 141) and PLC scrutiny of Bills (s 152(3)(a)) – Standing Orders and gazetting – locus standi – referral to High Court for factual inquiry into public hearings.
31 October 2018
Section 27 POSA’s one‑month blanket bans on demonstrations unjustifiably infringe the constitutionally protected right to demonstrate and petition peacefully.
Constitutional law – Freedom to demonstrate and petition – Section 59 requires peaceful exercise – Limitation of rights – Section 27 POSA permits blanket one‑month bans – Proportionality and necessity test under s86(2) – Blanket/dragnets arbitrary and disproportionate – Declaration of invalidity suspended for six months.
17 October 2018
August 2018
Applicant failed to prove material irregularities; court confirmed declared presidential winner and dismissed the challenge.
Election law – challenge to presidential election – presumption of validity of declaration – onus on aggrieved candidate – requirement for primary source evidence (sealed ballot boxes, V11 returns, recounts) – condonation for procedural non-compliance – minor data-capture errors do not vitiate declaration.
24 August 2018
July 2018
Direct access denied for non‑compliance with rules; resignation deemed voluntary; succession and impeachment held constitutional; applicants ordered to pay costs.
Constitutional law — direct access — strict compliance with rule 21(3); resignation of President — s 96(1) — presumption of voluntariness from signed written notice; impeachment — s 97 — parliamentary procedure; presidential succession — Sixth Schedule paras 14(4)(b), 14(5) and s 94; withdrawal of proceedings — invalid after matter set down without consent or leave; costs in constitutional litigation — abuse of process may attract costs.
16 July 2018
June 2018
Constitutional Court dismissed application for direct constitutional relief where administrative remedies and appeal routes were available.
Constitutional jurisdiction – avoidance and ripeness – subsidiarity – administrative law remedies under the Administrative Justice Act – improper direct access to Constitutional Court; disguised appeal; res judicata noted.
27 June 2018
May 2018
Ministerial approval of electoral commission regulations is an administrative sanction, not unconstitutional control over the Commission.
Constitutional law — Independence of commissions — Whether ministerial approval of electoral commission regulations constitutes "direction or control" — Interpretation of "approve" as administrative sanction — Parliamentary scrutiny of subsidiary legislation — Right to free and fair elections.
31 May 2018
A constitutional referral under s 175(4) is invalid where the Labour Court lacks jurisdiction because a designated agent already made a final decision.
Labour law – Compulsory conciliation under s 93 – Certificate of no settlement and draft ruling as preconditions for s 93(5a)/(5b) confirmation – Designated agent’s redress under s 63(3a) finalises dispute – Referral under s 175(4) requires matter validly before subordinate court.
30 May 2018
Applicants’ claim for a diaspora vote dismissed: Zimbabwe’s Constitution and Electoral Act establish a constituency-based system limiting overseas voting.
Constitutional interpretation – political rights and voter qualification – constituency-based electoral system – residency requirements (s 23 Electoral Act) constitutional – postal voting limited to state employees (s 72) not unfair discrimination – international treaties not self-executing without domestic incorporation.
30 May 2018
Direct access was refused; courts cannot interdict the President’s mandatory proclamation of election dates and s3(3) funding threshold is constitutionally permissible.
Constitutional procedure – direct access to Constitutional Court – necessity of leave under Rules; Constitutional duty – President’s mandatory obligation to proclaim election dates; Interdicts – unlawful to interdict lawful constitutional acts; Political parties funding – s67(4) does not require funding for all parties; Political Parties (Finance) Act s3(3) – rational threshold for funding; Prospects of success and interests of justice; Res judicata.
28 May 2018
March 2018
Religious schools may require managerial staff to be adherents; changing religion can justify reassignment without constitutional breach.
Freedom of religion — s60(1) and s60(4) — religious communities' right to establish schools and determine managerial qualifications; requirement that headteachers be adherents; change of religion as legitimate basis for reassignment; no infringement of equality or association rights; transfers as consequence, not penalty.
28 March 2018
October 2017
A constitutional challenge to a High Court costs order was procedurally premature; the applicant should have appealed to the Supreme Court first.
Constitutional law – costs orders – right to legal representation at own expense (s 69(4)) – challenge to taxation under S.I. 12/2011 (as amended by S.I. 107/2011) – jurisdiction of Constitutional Court – requirement to exhaust alternative remedies – doctrine of constitutional avoidance and ripeness – appeal to Supreme Court.
25 October 2017
September 2017
Alleged unlawful arrest must be challenged in the Magistrate's Court under statutory remedies; Constitutional Court lacked jurisdiction.
Constitutional jurisdiction — lawfulness of arrest — CP&E Act s25 and s41A — Anti-Corruption Commission Act s13 — ZACC powers — police secondment retains arrest powers — reasonable suspicion — principle of subsidiarity — remand (Magistrate's) court primary forum.
20 September 2017
Direct constitutional relief is improper where the same constitutional issues are pending before a subordinate court.
Constitutional procedure — direct access under s85(1)(a) — improper where same constitutional issue pending before subordinate court; s175(4) procedure; right to privacy (health status) in employment disciplinary context; Labour Court jurisdiction on lawfulness of dismissal.
20 September 2017
Constitutional challenge to insult-the-President provision; prosecution’s factual misdescription led to matter being struck off the roll.
Criminal law — section 33(2)(a) (insulting/undermining President) — constitutional challenge under freedom of expression — sufficiency and accuracy of charge — false statement must be capable of being believed and engender hostility — factual insufficiency — matter struck off the roll.
20 September 2017
July 2017
Pre‑trial torture does not automatically bar prosecution; a permanent stay is exceptional and factual disputes must be resolved before referral.
Constitutional law — Prohibition of torture — Pre‑trial ill‑treatment — Effect on validity of prosecution — Use of fruits of torture — Permanent stay of prosecution as an exceptional remedy — Remedies: damages or prosecution of perpetrators — Need to resolve material factual disputes before constitutional referral.
19 July 2017
Referral under s24(2) was defective because the magistrate failed to form the required opinion; matter struck off the roll.
Constitutional procedure — Section 24(2) former Constitution — duty of magistrate to form and state opinion whether constitutional question raised is merely frivolous or vexatious — referral defective if no proper analysis or formulation — criminal nuisance charge (para 2(f) v 2(v)) — striking off roll; need for magistrate/prosecutor remedial action.
12 July 2017
May 2017
Premature constitutional challenge struck off where Labour Court pending and statute authorizes impugned conduct.
Constitutional procedure — jurisdictional propriety — ripeness and avoidance — Labour Court jurisdiction under s46(b) — challenge to conduct authorized by statute requires challenge to statute’s constitutionality.
24 May 2017
March 2017
Court dismissed death‑row prisoners' delay challenge as premature, urging exhaustion of review, appeal and presidential pardon.
Constitutional law — jurisdiction; ripeness and constitutional avoidance; exhaustion of alternative remedies — administrative review of prison conditions; appeal to Supreme Court; presidential pardon/commutation; death penalty — ss 48, 51, 53.
20 March 2017
Referral flawed: magistrate failed to identify the constitutional question and the responsible Minister was not cited.
Constitutional procedure — referral under s175 — requirement to identify specific constitutional question and relevant facts — viva voce evidence generally required where facts disputed — lower court must apply mind to whether referral is frivolous or vexatious — Minister responsible for statute must be cited where final invalidity relief sought.
17 March 2017
A constitutional non obstante clause (s16B) permits state land acquisition that overrides treaty-protected property rights (s16(9b)).
Constitutional law — Land acquisition — Section 16B (agricultural land for resettlement) — Non obstante clause — Overrides Chapter III rights including section 16(9b) (treaty-protected property rights) — Acquisition intra vires Constitution.
16 March 2017
Magistrate’s refusal to refer constitutional question was unlawful; challenged statutory provisions and prosecution found constitutional.
Constitutional law — referral of constitutional question by magistrate — protection of law (s18(1)) — constitutionality of Criminal Law (Codification and Reform) Act s277(3) read with s277(5) — constitutionality of Gazetted Lands (Consequential Provisions) Act ss3(2),3(3) — lawfulness of prosecution — administrative deliberation (Workshop) and s18(2) rights.
16 March 2017
February 2017
Arresting an accused who freely attends court and detaining them in holding cells is unlawful absent lawful basis.
Constitutional law – Right to personal liberty – Unlawful arrest/detention – Arresting accused who freely attend court and placing them in holding cells – Requirement for lawful exercise of discretion to arrest (Muzondo factors) – Referral to Constitutional Court under s56(1) and s175(4).
28 February 2017
Application for stay refused, but trial quashed and ordered de novo due to magistrate conduct risking unfair trial.
Criminal procedure – exception to charge – right to be informed promptly of charge (s 70(1)(b)) – prohibition on retrospective criminalisation (s 70(1)(k)) – fair trial and impartial tribunal (s 69(1)) – perception of bias by trial magistrate – proceedings set aside and trial de novo ordered.
28 February 2017
Leave to appeal requires a constitutional issue actually decided below; obiter reference to s176 is insufficient.
Constitutional jurisdiction – leave to appeal – requirement that constitutional issue was raised and necessary in subordinate court; res judicata and functus officio – limits where currency conversion arises post-judgment; s 176 (inherent jurisdiction) – obiter reference does not create constitutional matter.
17 February 2017
November 2016
No jurisdiction where Supreme Court did not decide a constitutional matter; abusive appeal attracts attorney‑client costs.
Constitutional Court – jurisdiction – direct appeal from Supreme Court – constitutional matter defined (s 332) – no jurisdiction where Supreme Court did not decide constitutional issue – abuse of process – attorney‑client costs.
23 November 2016
A vague charge violated the applicant’s right to the protection of the law; alleged conduct did not constitute s33(2)(a) offence.
Criminal law — Undermining authority of President — s 33(2)(a) — Elements: false statement, knowledge of falsity, intent to engender hostility and likelihood to deceive — Vagueness of charge — Right to protection of the law (s 18(1)) — s 139 Criminal Procedure and Evidence Act — Personal liberty (s 13(1)).
23 November 2016
The applicant cannot invoke the Constitution directly where the Labour Act and CBA provide statutory remedies.
Labour law; right to fair and safe labour practices (s 65); collective bargaining agreement (S.I. No. 67/2012); subsidiarity principle; statutory remedies under the Labour Act; limits of Constitutional Court jurisdiction.
16 November 2016