Harare High Court - 2006

122 judgments
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122 judgments
Citation
Judgment date
December 2006
A notice of appeal failing to state the relief sought is incurably defective and leads to the appeal being struck off the roll.
Civil procedure – Appeal – Notice of appeal must state exact relief sought – Defective notice of appeal is incurably bad and cannot be validated by later grounds or heads – Proper remedy is application for condonation and filing a proper notice – Litigant bears consequences of attorney’s negligence.
31 December 2006
Court grants divorce, awards mother custody and relocation rights, finds father hid assets, orders specific asset division and costs.
Divorce — Custody: sole custody to mother where parental acrimony, lack of trust and manipulation make joint custody impracticable — Expert psychological reports influential; child welfare paramount. Removal/relocation: mother permitted permanent removal of children to UK after specified date. Matrimonial assets: court requires full and frank disclosure; adverse inference for evasive conduct; court will not abrogate jurisdiction to foreign courts — allocation of specified properties and proceeds. Maintenance and interim arrangements regulated by consent order; costs including expert fees awarded to successful party
19 December 2006
Review of taxation dismissed: attorney authorised; Taxing Officer not clearly wrong; application dismissed with costs.
Civil procedure — Review of taxation — Rule 314 governs taxation reviews; Rule 257 not applicable — Authority of legal practitioner to depose on behalf of litigant — Standard for interfering with Taxing Officer (gross unreasonableness/clearly wrong) — Costs consequent to postponement — Discretion on higher scale and de bonis propriis costs.
19 December 2006
Specific performance refused because payment abroad breached exchange control; provisional liquidation granted for just and equitable deadlock.
Exchange control – contract requiring payment abroad – illegality and unenforceability; Contract performance – mora ex persona and requirement of demand before repudiation; Specific performance – refusal where contract illegal; Companies – provisional winding-up on just and equitable ground (deadlock/mismanagement); Recusal application – prior arbitrator acting as counsel and conflict of interest
5 December 2006
November 2006
Court granted leave to execute pending appeal, finding the Deputy Sheriff erred and the respondent’s appeal lacked prospects.
Civil procedure – Execution pending appeal – Leave to execute pending appeal – Discretionary equitable remedy – Factors include prospects of success, irreparable harm and balance of convenience (Tranos Toziva test); Sheriff’s duties – Section 20(1) High Court Act – duty to execute writs; improper halting of execution by Sheriff; appeal frivolous and lacking prospects
30 November 2006
The applicant’s conviction under UK institute bye‑laws was set aside because those rules are not applicable domestically.
Professional discipline — applicability of foreign institute’s Charter and Bye‑laws — constituent bodies under Public Accountants and Auditors Act — ministerial approval and gazetting of by‑laws — invalidity and nullity of proceedings — court entitled to raise applicability mero motu
29 November 2006
An article alleging misconduct of a public figure was defamatory; privilege and justification failed due to reckless, unverified publication.
Defamation — defamatory meaning; public-figure reporting; privilege — limits and abuse (reckless publication, failure to verify unsigned minutes, omission of comment); justification — burden to prove substantial truth and public benefit; damages assessed with regard to comparable awards and currency revaluation
29 November 2006
Maintenance assessed by earning capacity where resignation was a ploy to avoid obligations; father ordered to pay $150,000 per child.
Family law – Divorce – Maintenance – Resignation to avoid maintenance – Court may assess maintenance by reference to earning capacity rather than reduced actual earnings – Application of share-allocation guideline (Gwachiwa/Beswick) – Custody and ancillary matters regulated by recorded settlement.
21 November 2006
Appeal allowed; eviction set aside due to material factual disputes, questionable Certificate of Authority, and need for oral evidence on tenancy.
Procedure — eviction proceedings — application vs summons where material disputes of fact; Estates — Certificate of Authority validity and Master’s jurisdiction; Review — High Court’s power to review patent irregularities on appeal; Tenancy — lease under power of attorney and statutory tenancy on co-owner’s death; Joint ownership and entitlement to occupation.
14 November 2006
Whether a magistrate may sentence under s334(7) when the trial magistrate is not truly "absent"; held improperly assumed jurisdiction.
Criminal procedure – section 334(7) – assumption of sentencing jurisdiction – meaning of "in the absence of the magistrate who convicted the offender" – assessment by time, space and circumstances – need to consider recorded evidence and opportunity to address in mitigation – jurisdictional defect remedied by setting aside sentence and remitting for re-sentencing.
14 November 2006
Prior judgment ordering transfer subject to interest precludes later cancellation; res judicata upheld, claim dismissed.
Res judicata – special plea in abatement – prior judgment ordering transfer subject to interest – election to abide by contract – exception timing and procedural irregularity.
14 November 2006
Taxing officer’s allowance of counsel’s fees as a reasonable disbursement upheld; terminology repeal did not remove tariff distinction.
Taxation of costs — disbursements to counsel instructed by a legal practitioner — Order 38 Rule 308 — taxing officer’s discretion and review under Rule 314 — repeal of "advocate/attorney" terminology does not abolish tariff distinction — High Court (Fees and Allowances) (Amendment) Rules 2003 para 8
7 November 2006
Adulterous partner found to have known husband was married; plaintiff awarded damages for contumelia and partial loss of consortium.
Adultery damages – knowledge of marital status – ‘diligent ignorance’ – continuation of adulterous relationship after summons – loss of consortium and contumelia – assessment and quantum of damages
7 November 2006
Whether a provincial magistrate has jurisdiction to determine surviving-spouse status under the amended Administration of Estates Act.
Administration of Estates Act (Act No. 6 of 1997) – Part IIIA – repeal of section 68 – jurisdiction of provincial magistrate to determine intestate customary-law succession disputes withdrawn – Master’s powers and appealability of Master’s decisions – referral by executor – nullity of magistrate’s ruling – condonation refused where Master not a party
7 November 2006
Mandatory minimum sentencing under the Stock Theft Act requires explanation and recording of special circumstances; failure requires resentencing.
Criminal law – Stock Theft Act (Chapter 9:18) – mandatory sentencing under s12 – requirement to explain and record "special circumstances" – particulars of offence in charge sheet – separation of trials and proper record-keeping.
7 November 2006
Property acquired during the marriage found jointly owned; husband awarded half the monetary value following valuation.
Matrimonial property — Division of matrimonial assets — Credibility of competing accounts of contribution — Joint acquisition found — Equal division and valuation procedure ordered.
7 November 2006
The applicant lacked locus standi to seek a VAT-exemption declarator on behalf of stockbrokers; application dismissed with costs.
Administrative law – locus standi – standing to sue on behalf of others – public interest v private interest litigation – requirement of direct and substantial legal interest; Tax law – VAT exemption claim by stockbrokers – representative application by non-members.
7 November 2006
October 2006
Driver’s negligence attracts vicarious liability; plaintiff’s delay in repairs limited recoverable damages despite defendant failing to prove contributory negligence.
Motor vehicle collision — vicarious liability for driver’s negligence — contributory negligence (onus on defendant) — mitigation of loss; delay in repairs; quantification of damages; repair estimates and evidence of spare parts availability
31 October 2006
Residuary beneficiaries lacked locus standi to vary the will; the trust remains capable of formation and disputed shares require further evidence.
Wills — locus standi of residuary beneficiaries to seek variation; Trust formation — testamentary trustee, executor may act as trustee; Administration of estates — recourse to the Master and statutory remedies; Property disputes — ownership of shares requires evidential proof, Companies Act presumption not determinative here
31 October 2006
An acknowledgement of debt does not waive the in duplum rule absent evidence of a genuine compromise or informed waiver.
In duplum rule – acknowledgement of debt – compromise and waiver – whether an AOD displaces in duplum – interest capped at capital – default judgment
31 October 2006
Court dismisses challenge to will as unarguable, holding will revoked prior wills and no evidence of undue influence.
Succession — validity of will — alleged undue influence — long‑term pressure versus influence at execution — construction of revocation clause — Order 11 dismissal for frivolous or vexatious actions; burden on alleging party to prove undue influence.
31 October 2006
Urgency requires objective irretrievable prejudice; eviction applications must cite and afford hearing to actual occupiers.
Civil procedure — Urgent applications — objective test of urgency: need to act when matter cannot wait because delay causes irretrievable prejudice — distinction between interim protective relief and final relief — necessity to cite actual occupants in eviction proceedings
30 October 2006
Whether an oral agreement created a binding sale when parties disagreed on inclusion of tender boats and Reserve Bank clearance.
Contract formation — consensus ad idem; oral agreement; sale of vessel; inclusion of tender boats as essential term; Reserve Bank clearance as condition precedent; no unequivocal acceptance — absolution from instance
24 October 2006
Dispute over pledged shares falls within Debenture Trust Deed arbitration clause; proceedings stayed and referred to arbitration.
Arbitration clause; Debenture Trust Deed; definition of Security; pledge and appropriation of shares; material non‑joinder (liquidator); stay and referral to arbitration under Model Law Article 8(1)
22 October 2006
Payment to a seller's (unregistered) agent transfers ownership on delivery; unregistered agents hold funds as account-holder's money.
Property law — ownership of money — payment to agent effects transfer on delivery; unregistered estate agency — no trust account; tracing/commixtio of funds in bank account
12 October 2006
Failure to justify late filing of notice of opposition and heads of argument led to automatic bar and summary judgment in default.
Civil procedure – summary judgment – notice of opposition filed out of time – condonation – requirement of reasonable explanation and supporting affidavit from practitioner – prospects of success – lis pendens argument – late heads of argument – automatic bar – summary judgment granted in default.
12 October 2006
Applicant’s failure to show irreparable harm and to provide security for costs led to dismissal of the urgent application.
Forestry seizure of goods – urgent chamber application – urgency requires irreparable prejudice – peregrinus/security for costs – review procedure (Order 33) and proper citation of Attorney-General/Minister.
11 October 2006
Failure to give reasons for a maintenance decision vitiates the order and warrants remittal for a fresh inquiry.
Judicial duty to give reasons — absence of reasons vitiates judgment and frustrates appeal — maintenance proceedings — remittal for fresh inquiry under s8 Maintenance Act — procedural fairness; effect of inflation on remedy
10 October 2006
Failure to give reasons for a maintenance decision vitiates the order and warrants a fresh s8 inquiry given changed circumstances.
Civil procedure — Maintenance variation — Requirement that courts give reasons for decisions — Absence of reasons vitiates order — Remedy: set aside and remit for fresh inquiry under s 8 Maintenance Act — Effect of inflation on maintenance orders — Costs where decisive point raised mero motu
10 October 2006
Parol evidence cannot introduce an oral suspensive condition; cancellation without demand was invalid; specific performance ordered.
Contract for sale of land; parol evidence rule; oral suspensive condition precedent inadmissible; seller must put purchaser in mora before cancellation; specific performance and Deputy Sheriff authorised to sign transfers
9 October 2006
Acceptance of a severance package while seconded amounted to implied waiver of right to reinstatement and arrears.
Labour law – secondment – employee remains employed by original employer; retrenchment and severance – acceptance of severance as implied waiver of employment rights; waiver by conduct; unjust enrichment.
4 October 2006
A s7 matrimonial redistribution claim is a personal right and does not survive to be enforced by a deceased spouse’s executor.
Succession – appointment and removal of executor dative – administrative role of the Master; Matrimonial Causes Act s7 – redistribution claims are personal (in personam) not real rights – non‑transmissibility after litis contestatio; validity of marriage – customary marriage status and Registrar of Marriages’ investigatory role
3 October 2006
September 2006
Accused's confirmed confession, eyewitness and medical evidence established intent; self-defence rejected and convicted of murder with actual intent.
Murder – mens rea inferred from single wound to a vital part of the body; Self-defence – requirements of unlawfulness, imminence, necessity and proportionality; Admissibility and evidential weight of a confirmed warned and cautioned statement; Post-mortem evidence – blunt force trauma to skull; Eyewitness evidence corroboration.
30 September 2006
An unregistered customary-law spouse is a statutory spouse for estate and pension purposes; both customary and civil wives share entitlement.
Succession and pensions – recognition of unregistered customary-law marriages for estate purposes – Administration of Estates Amendment Act No.6 of 1997 – effect of subsequent civil marriage – pension fund rules versus statutory recognition of customary spouses
19 September 2006
A lawyer’s letter accusing a senior military officer of abusing office was held maliciously defamatory; plaintiff awarded damages, counterclaim dismissed.
Defamation – publication by lawyer’s letter – imputations of abuse of office and misuse of military personnel – malice – credibility of witnesses – assessment of damages for defamation of senior state/military official.
19 September 2006
Creditor failed to prove the individual respondent committed an act of insolvency or that sequestration would benefit creditors.
Insolvency law – sequestration – act of insolvency (s11(f)) – definition of ‘debtor’ – corporate personality and veil-piercing – onus on creditor to prove advantage to creditors for sequestration – insufficiency of payments-to-company evidence.
12 September 2006
Sequestration dismissed: applicant failed to prove the respondent was a debtor or committed an act of insolvency; corporate payments not attributed to him.
Insolvency — sequestration — meaning of "debtor" under Insolvency Act — s11(f) act of insolvency (suspension/notice) — advantage to creditors (s13) — piercing corporate veil — attribution of company payments to individual debtor.
12 September 2006
August 2006
Loan held payable in US dollars; ZW$ tender did not discharge debt; costs awarded on ordinary scale.
Foreign-currency judgments — implied currency of payment; Tender in local currency — insufficient without creditor's agreement; Official versus parallel exchange rate — unfair enrichment concern; Costs — ordinary scale where clause not specific.
23 August 2006
An employer is not vicariously liable where an employee carried unauthorised passengers in breach of a prohibition limiting his employment sphere.
Vicarious liability — unauthorised passengers — prohibition limiting sphere of employment — frolic of his own — test of degree — employer not liable
22 August 2006
Spousal maintenance and a life usufruct awarded where matrimonial property largely excluded due to prior inheritance and limited marital contribution.
Divorce – spousal maintenance – assessment of quantum and duration (until death or remarriage) – matrimonial property – exclusion of inherited or pre-marriage shares under s7(3) Matrimonial Causes Act – life usufruct as alternative relief – res judicata and prior magistrates’ maintenance application.
22 August 2006
An inadequately pleaded review alleging bias and gross irregularity failed where the magistrate's credibility findings were reasonable.
Criminal procedure – Review under High Court Act ss 26–27 – adequacy of grounds pleaded – bias and gross irregularity – credibility findings – handwriting expert evidence not required where signature undisputed – review inappropriate where appeal available.
15 August 2006
Applicant granted spoliation relief restoring possession of employer-issued vehicle wrongfully repossessed by respondent.
Spoliation — unlawful dispossession — employer's self-help — restoration of status quo ante — peaceful possession and forcible deprivation — interim possession order
8 August 2006
"Lawful issue" in a mutual will includes children born out of wedlock if recognized by law and by the testator.
Succession — mutual will — interpretation of "lawful issue" — whether term includes extra‑marital children recognised by law and the testator — armchair rule of construction — beneficiaries to benefit equally.
8 August 2006
Delay in psychiatric examination attributed to accused; bail refused due to serious charges and risk to public safety.
Criminal procedure – bail – refusal where accused charged with multiple murders and claims of diminished responsibility; delay in psychiatric examination – attribution of delay to accused; right to a fair hearing within reasonable time – accused’s responsibility to pursue special defence evidence; no court order for psychiatrist where registrar’s letter merely requested mental examination.
1 August 2006
Where arbitration cannot produce an enforceable cancellation of registered title, the High Court may hear the dispute despite an arbitration clause.
Arbitration clause – Jurisdiction of High Court; Deeds Registry Act s8(1) – cancellation of registered transfer only by court order; Arbitration Act (Act 6 of 1996) Article 35 – enforcement of awards (no conversion to court judgment); unenforceability of arbitral awards to effect cancellation of registered title; court may hear matter where arbitration would be futile.
1 August 2006
July 2006
Barring for failure to plead requires serving Form No.9 and filing its endorsed copy; the bar is not automatic and defective procedure defeats default judgment.
Civil procedure – barring for failure to plead – Order 12 Rules 80–81 and Form No.9 requirements – bar not automatic; distinction from automatic bar for failure to enter appearance (Rules 17 and 50) – effect of defective endorsement and late filing on entitlement to default judgment
27 July 2006
Non-compliance with S.I.371/85 rendered the applicant's suspension a nullity and entitled him to back pay.
Labour law – Suspension without pay – Statutory Instrument 371/85 s3(1) – requirement to apply 'forthwith' to Labour Officer – failure renders suspension nullity; Repeal by S.I.130/2003 – inability to cure; Procedural bar – late filing of opposing papers.
25 July 2006
Divorce granted; court held war-compensation-funded house was matrimonial property and distributed the two homes equitably.
Family law – Divorce – irretrievable breakdown – Matrimonial Causes Act s7 – distribution of matrimonial property – exclusion of assets of particular sentimental value – contributions (financial and non-financial) to acquisition and improvement – equitable apportionment of immovable property.
25 July 2006
Exemption clauses do not shield the defendant from liability for gross negligence; plaintiff awarded inflated replacement value.
Contract law – security services – guard negligence and supervisory failures – fundamental breach/gross negligence – exclusion clauses inapplicable; Damages – replacement value in hyperinflation; mitigation of loss.
25 July 2006
Applicant failed to prove supplier-export under VAT Act; Commissioner wrongly cited; application dismissed with costs.
Tax law – VAT zero-rating of exports – meaning of “exported” (consigned/delivered by supplier to address in export country) – onus on supplier to prove export status; Civil procedure – correct party to sue – Zimbabwe Revenue Authority v Commissioner General; Administrative law – estoppel against State officials; Delegated legislation – regulations ultra vires and non‑retrospective; Pleading – new cause of action cannot be raised in heads of argument.
25 July 2006