Harare High Court - 2016 May

42 judgments
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42 judgments
Citation
Judgment date
May 2016
A magistrate cannot decide contested merits at a pre-trial conference where parties have not agreed; matter remitted for proper pre-trial.
Civil procedure — Pre-trial conference — Order 19 Magistrates' Court (Civil) Rules — purpose is case-management and settlement, not determination on merits — magistrate’s misdirection in ordering eviction at pre-trial where parties not ad idem — remittal for proper pre-trial conference.
31 May 2016
Payments to accounts nominated by a fraudster did not discharge the defendant’s debt; Turquand rule inapplicable where no actual agency.
Contract for supply of goods – payment into varied bank accounts – fraud by third party purporting to be company agent – apparent authority and Turquand rule inapplicable where fraudster not authorised – company not bound by fraudster’s representations
30 May 2016
Applicant awarded 70% of the matrimonial home after respondent's long desertion; needs and conduct outweighed contributions.
Matrimonial property division — s 7 Matrimonial Causes Act — needs and expectations versus direct contributions — desertion/abandonment — valuation and buy-out option — 70:30 award of matrimonial home.
26 May 2016
Concessionary school-fees for employees’ children constitute a taxable employment benefit; valuation is by employer’s cost, but waived amounts were upheld for PAYE assessments, with limited reassessment where children attended other schools.
Income tax — Benefit in kind — Waiver of school fees for employees’ children — Whether concessionary schooling is an "advantage or benefit" under s 8(1)(f) (and s 8(1)(b)) — Valuation of benefit: cost to employer versus waived amount — PAYE withholding liability of employer — Assessments where benefit arises from inter-school agreements
20 May 2016
Spoliation refused where applicants failed to prove statutory or constitutional authority to occupy gazetted agricultural land.
Spoliation — Gazetted Lands (Consequential Provisions) Act — unlawful occupation of gazetted land — meaning of "lawful authority" (offer letter, permit, lease) — s 291 Constitution (continuity of occupancy rights) — necessity to prove lease or agreement with State — courts will not assist litigants acting in defiance of statute.
19 May 2016
Claimant failed to prove ownership of goods attached in execution; claim dismissed with costs.
Interpleader proceedings – onus on claimant to prove ownership – invoices insufficient proof of delivery or transfer – property in judgment debtor’s possession – registration of trust not determinative.
19 May 2016
Whether an overly evidentiary, prolix declaration should be struck out and whether an arbitration clause ousts court jurisdiction.
Civil procedure – Pleadings – Exception and strike out – Voluminous, evidentiary and prolix declaration contrary to r 99 – Defendant entitled to concise statement of material facts; Arbitration – Arbitration clause versus non‑exclusive jurisdiction clause – Arbitration not mandatory absent clear intention that it be first instance procedure
18 May 2016
Plaintiffs failed to prove a lease or meeting of minds with the defendant; claim for arrears and eviction dismissed.
Contract law – Lease – existence of lease – offer and acceptance; meeting of minds; privity of contract; proof of terms; improvements and claim for set-off/lien; entitlement to arrears, holding-over damages and eviction
18 May 2016
Summary judgment refused where lis pendens and unclear identity of the cause of action between related suits raised triable issues.
Civil procedure – summary judgment – lis pendens/res judicata – multiplicity of actions – guarantor liability; necessity of clarity on cause of action and security before granting summary judgment
18 May 2016
Applicant failed to show prima facie entitlement to stay execution pending rescission; execution allowed.
Civil procedure — urgent application for stay of execution pending rescission of default judgment — joint and several liability; res judicata; requirements for interim interdict — prima facie right; irreparable harm; balance of convenience
18 May 2016
Court declared applicants lawful shareholders, refused direct transfer of company property, found respondent barred and practitioner’s affidavit unauthorised.
Civil procedure — service at domicilium by placing in letterbox — return of service prima facie proof — r 233(2) bar for failure to file opposing papers — authority required for practitioner to depose and oppose (r 227) — disputed entitlement to company shares vs direct transfer of company property — company property dealt with under Companies Act
18 May 2016
The appellant’s eviction claim was not prescribed and suing the respondent (not the estate) was appropriate; absolution was wrongly granted.
Property law – eviction – cause of action arises when owner becomes aware of material facts; prescription – continuous wrong doctrine; Civil procedure – absolution from the instance – inappropriate where plaintiff proves material facts to require defendant’s answer; Succession/representation – estate not necessary party where property was alienated in deceased’s lifetime and surviving spouse exercises de facto control
18 May 2016
Bank’s sale of immovable security without satisfying s 38 prerequisites and joining registered title holder was unlawful.
Agricultural Finance Corporation Act s 38 – statutory powers to take possession and sell security – s 38(2) subject to s 38(3) and events in s 38(1)(c),(d),(e) – immovable property – unlawful self-help – protection and joinder of third-party title holder.
18 May 2016
Buyer entitled to refund and improvement costs (less borehole vandalism); seller’s forfeiture and reconvention claims failed.
Instalment sale of land – enforceability of forfeiture/penalty clauses – parole evidence and s 7 Contractual Penalties Act – proof of oral terms – damages for unauthorised alterations and vandalism – assessment of relief under s 9(3).
18 May 2016
Last‑minute challenge to execution was not urgent; matter removed from roll and costs awarded against the applicant.
Urgency — self-created urgency; Order 40 r 331 — joinder of creditors in execution and participation in proceeds; Provisional sentence — effect of tax directive; Stay of execution — prerequisites and delay; Abuse of process; Certificate of urgency requirements.
18 May 2016
Challenge to arbitral award on public policy grounds dismissed where applicant’s arbitration concession established the loan’s validity.
Arbitration — setting aside arbitral award — public policy (Article 34(2)(b)(ii) Model Law) — concession in arbitration — acceptance of cession implies acceptance of underlying instrument — mere error of law/fact insufficient; must be palpable inequity — new issues not raised before arbitrator inadmissible on review.
18 May 2016
An application to rescind a judgment previously challenged and dismissed is barred by res judicata; costs de bonis propiss awarded.
Rescission of judgment – res judicata – functus officio – prior unsuccessful rescission bars subsequent application seeking same relief – default judgment remains binding until set aside or appealed; costs de bonis propiss; referral to Law Society.
18 May 2016
Claimant failed to prove ownership of goods attached in execution; attachment confirmed and costs awarded.
Interpleader/attachment in execution — onus on claimant to prove ownership of attached goods — proof on balance of probabilities — inconsistent dates and lack of documentation fatal to claim — attachment confirmed; costs on legal practitioner and client scale.
18 May 2016
Tenant breached lease by cutting trees without consent; plaintiff awarded commercial-value damages; reconventional claims dismissed.
Lease law – tenant bound by signed written lease despite clerical errors (caveat subscripto) – unlawful cutting of trees in breach of lease – valuation of trees (commercial quotations v Forestry Commission) – malicious prosecution requires malice; acquittal alone insufficient – defamation requires proof of publication.
18 May 2016
Whether a 2013 agreement and conduct interrupted prescription for an earlier unpaid commercial debt under the Prescription Act.
Prescription Act — s15(d), s16: period and commencement of prescription for debts — s18: interruption by express or tacit acknowledgment — commercial conduct (supplying on cash-on-delivery while servicing old debt) can constitute acknowledgment interrupting prescription.
18 May 2016
Court upheld rape conviction based on child testimony and medical signs of penetration, dismissing appeals against conviction and sentence.
Evidence — credibility of child witness; Sexual offences — proof of legal penetration; Medical evidence — hyperpigmentation as corroboration; Evaluation of child testimony — cultural and developmental considerations; Sentencing — appropriateness of 14-year term for rape.
18 May 2016
Employee's conviction for theft of trust property upheld on cumulative circumstantial evidence and breach of cash-handling duties.
Criminal law – Theft of trust property – Circumstantial evidence – Duty to account for money received in course of employment – Standard of proof beyond reasonable doubt – Conviction on cumulative circumstantial facts appropriate where alternative explanation not reasonably possible.
18 May 2016
Seller convicted of fraud for misrepresenting availability of land already ceded to another purchaser.
Criminal law – Fraud – Double sale/cession of rights in State land – Misrepresentation as to availability of land – Knowledge and intention to induce purchaser – Circumstantial evidence and credibility findings – Non‑calling of complainant/executor not necessarily fatal – Amendment of charge to identify actual prejudiced person.
18 May 2016
Conviction quashed where the State failed to prove the prevailing international cross rates, an essential element of the offence.
Exchange control — Adherence to international cross rates — Whether the prevailing international cross rate is an essential element of the offence — Prosecution obligation to prove applicable cross rate — Effect of failure to lead such evidence on safety of conviction.
18 May 2016
Failure to give 60‑day statutory notice is fatal to proceedings against ZIMRA, which is an agent of the State.
Customs and Excise Act s196 – mandatory 60‑day notice to sue the State/Commissioner/officer – ZIMRA as agent/organ of State – failure to give notice fatal to proceedings; preliminary point in limine upheld.
18 May 2016
Urgent stay of execution struck off for unexplained delay; bank consent to bond cancellation undermined applicant's position.
Civil procedure — Urgent chamber application — urgency requires explanation for delay; execution — stay of sale in execution pending realization of proceeds; mortgagee consent — misrepresentation affecting bond cancellation; costs for non-urgent applications.
12 May 2016
Applicants failed to prove possession required for mandament van spolie; application dismissed with ordinary costs.
Property law – mandament van spolie – requirements of peaceful and undisturbed possession and unlawful deprivation – evidentiary burden – joint possession not pleaded – lease and receipts as evidence of possession
11 May 2016
Applicant's delay and failure to seek tax deductions at quantification rendered its urgent application for stay of execution inadmissible.
Urgency—self-created urgency and delay in launching urgent relief; Tax law—employer's duty to deduct and remit income tax at quantification stage; Court orders—finality of court orders and limits on post-judgment tax directives; Pleading—material non-disclosure does not automatically invalidate urgent relief but may attract censure.
11 May 2016
A liquidator must obtain court leave under s221(2) to continue litigation; guarantees based on a non-existent principal are invalid.
Companies law – liquidation – s 221(2) – liquidator must obtain leave of court to bring or continue proceedings; Locus standi – substitution notice insufficient; Contract and suretyship – principal debtor non-existent — guarantees and mortgage security premised thereon invalid; Prescription – general three-year rule; mortgage-secured debts thirty-year prescription; burden to prove date of default.
11 May 2016
Whether the Minister may lawfully suspend a mayor under s114 pending Parliament’s enactment of s278’s independent-tribunal regime.
Constitutional law; local government; Urban Councils Act s114 (suspension/investigation) validated; Constitution s278 (removal) requires Parliament to establish independent tribunal; suspension distinct from removal; Minister may lawfully suspend but cannot dismiss without statutory tribunal.
11 May 2016
Urgent application to eject occupiers from mining claims struck off for lack of urgency due to inexcusable delay.
Urgent chamber application — urgency and unreasonable delay; certificate of urgency — who may sign; procedural compliance — Form 29C; statutory remedies under Mines and Minerals Act (not decided).
11 May 2016
Court found prescription raised factual disputes and referred the matter to trial; procedural set-down was sufficient.
Procedure – Order 21 r138 – setting down special pleas and exceptions; Prescription – whether prescription can be decided on the papers or requires evidence where factual disputes exist; Exception – sufficiency of declaration, vagueness and caveat subscriptor issues; referral to trial where material facts are disputed.
11 May 2016
Appointment of an administrator without the statutory inquiry, report and consultation breached administrative justice and was declared unlawful.
Co-operative Societies Act ss 113 & 120 — statutory inquiry and report required before appointment of administrator; Administrative law — s 68 Constitution and Administrative Justice Act s 3 — right to reasons, consultation and fair administrative process; Locus standi — management committee recognised by Ministry; Declaratory relief and invalidation of administrative action.
11 May 2016
Claimant proved ownership of most attached property; Mercedes E200, television and fridge declared executable.
Interpleader — attachment pursuant to execution — ownership of goods acquired in prior marriage — claimant’s burden of proof on ownership — credibility and falsehoods concerning specific items — declaration of executability of certain items.
11 May 2016
Request to refer recusal and fair‑hearing questions to the Constitutional Court dismissed as frivolous; no reasonable apprehension of bias shown.
Constitutional procedure – s 175(4) referral – meaning of constitutional matter (s 332) – requirement for evidential basis for referral (Mwonzora) – procedural propriety of notices – frivolous and vexatious standard for referrals – recusal and reasonable apprehension of bias – judicial independence and dual administrative/judicial roles of Chief Justice.
11 May 2016
Judge may hear urgency despite another judge's prima facie non‑urgency endorsement; provisional expulsion challenge not urgent due to adequate internal remedies.
Civil procedure — Urgency: requirements and irreparable harm; internal remedies — association disciplinary procedures and Congress as satisfactory alternative; jurisdiction — another judge may hear urgency where initial endorsement was prima facie and judge indisposed; review relief not suited to urgent roll; access to courts and fair hearing considered.
10 May 2016
Accused convicted of murder; diminished responsibility plea rejected for lack of medical proof and pervasive dishonesty.
Criminal law — Murder (s 47(1)(a)) — death by asphyxia/broken larynx — evidence of intent — confirmed warned and cautioned statement — s 314 uncontroverted evidence — diminished responsibility (s 218) not established — credibility of accused.
10 May 2016
An unsuspended arbitral award should be registered for enforcement unless stayed, set aside, or successfully appealed.
Arbitration — Registration and enforcement of arbitral awards — Pending appeal does not suspend execution absent a stay — Labour Act s 92E(3) — Registration not a review or appeal
9 May 2016
Former employee lacked a bona fide defence and locus standi to challenge the will; summary judgment for eviction and costs granted.
Succession law; summary judgment — bona fide defence; locus standi to challenge a will; occupation by former employee; eviction from deceased's estate property.
4 May 2016
A statutory disciplinary order is a judgment in a broad sense but not a 30-year judgment debt; the claim had prescribed.
Health Professions Act s117 – recovery of costs and penalties ordered by regulatory disciplinary committees; Quasi-judicial tribunals – determinations as "judgments" in a broad sense; Judgment debt vs cause of action – distinction for prescription; Prescription Act – commencement of prescription and applicable periods; Enforcement procedure – need for court action to obtain executable judgment.
4 May 2016
Claims arising by June 2011 prescribed; arbitration does not interrupt prescription and lis pendens upheld for remaining claim.
Prescription Act s15(d) — three‑year prescription for contractual/delictual debts; s19 — judicial interruption of prescription does not include arbitration; s17 — arbitration delays prescription only if claim validly referred in terms of reference; lis pendens — pending labour arbitration/appeal precluded High Court adjudication of award-related claim.
4 May 2016
Insufficient evidence of fraudulent misrepresentation and no binding BSGR guarantee; accused acquitted and discharged.
Criminal law – fraud – misrepresentation as essential element; corporate veil inapplicable to personal criminal liability of directors; conditional offers versus acceptance; parol evidence rule and written contracts; sufficiency of evidence and inspection in loco.
4 May 2016