Harare High Court - 2017

331 judgments
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331 judgments
Citation
Judgment date
December 2017
Bail pending appeal refused where guilty plea was properly canvassed, appeal had poor prospects, and abscondment risk was high.
Bail pending appeal — prospects of success vs risk of abscondment; guilty plea — proper canvassing of essential elements; mandatory minimum sentence — "special circumstances"; afterthought defence and mitigation evidence.
13 December 2017
November 2017
Per stirpes succession permits grandchildren of a predeceased child to inherit by representation under both common and customary law.
Succession law — per stirpes (representation) — intestate succession — applicability under common law and customary law — Administration of Estates Act s68F — vesting at death — grandchildren of predeceased child entitled to inherit.
29 November 2017
29 November 2017
September 2017
Conviction upheld but review certificate withheld due to defective record, improper restitution order, and manifestly lenient global sentence.
Criminal law – fraud and theft of trust property – recording of plea and endorsement of sentence – requirement to endorse sentence and record individual sentences – restitution to corporate complainant (not representative) – manifestly lenient/global sentence – review and withholding of certificate.
27 September 2017
August 2017
Court substituted prospecting convictions for possession where facts showed ore removal and protected unrepresented accused facing mandatory sentences.
Criminal law – Mines and Minerals Act – distinction between prospecting and possession/removal of ore – plea of guilty procedure – rights of unrepresented accused facing mandatory minimum sentences – substitution of conviction and sentence on review.
3 August 2017
Accused convicted of murder; provocation and diminished responsibility not established; sentenced to 20 years imprisonment.
Criminal law — Murder v provocation — Whether loss of self-control/diminished responsibility established — Credibility of child witness — Post-mortem evidence (head trauma) — Foreseeability of death/constructive intent (s47(1)(b)).
2 August 2017
July 2017
Accused convicted of murder; provocation and self-defence rejected, voluntary intoxication mitigatory only, sentenced to 15 years.
Criminal law – Murder (s 47(1)(b)) – Provocation and self‑defence – Constructive intent/realisation of risk – Voluntary intoxication mitigatory only – Gender‑based violence considered in analysis and sentencing.
31 July 2017
Rescission granted for a default judgment where a fundamental identity error occurred; execution judgment not rescindable as applicant attended the hearing.
Civil procedure – Rule 449(1)(a) – Rescission of judgments erroneously sought or granted; identity/joinder errors; presence of party bars rescission; res judicata requires same parties; delay in bringing rescission applications.
26 July 2017
Registration of an arbitral award is proper where the award is extant and duly quantified; jurisdictional objections should be pursued by appeal or review.
Arbitration — Registration of arbitral award — s98 Labour Court Act — requirements for registration (party, award relates, certified copy) — award must be extant — quantification/amendment of award — functus officio and jurisdiction to correct/quantify — prescription and abuse of process.
26 July 2017
June 2017
Misnaming of the principal debtor was non-material and correctable; rescission of the default judgment refused.
Rescission of judgment – Rule 449(1)(a) – misdescription of party name – non-material error – correction vs rescission; locus standi of merged/liquidated company; proof required to impugn default judgment.
30 June 2017
An out‑of‑time purported amendment introducing a fresh appeal against conviction is a nullity; mistake of law did not excuse mandatory sentence.
Criminal procedure – Appeals – Amendment of notice of appeal – Distinction between permissible amendment and introduction of a fresh, out‑of‑time appeal – Rules 6 and 22; Gold Trade Act – Possession of gold without permit – Mandatory minimum sentence – Reasonable mistake of law not established – "Special circumstances" absent; Review powers – Not exercised where appeal is incompetent.
29 June 2017
Court refused absolution, finding prima facie locus standi and an acknowledgement of debt, and ordered the trial to continue.
Civil procedure — Absolution from the instance — Test at close of plaintiff's case — Locus standi of parent company to sue for subsidiary’s claim — Acknowledgement of debt — Prima facie evidence — Trial to proceed.
28 June 2017
Municipal by‑laws do not permit removal of leased advertising structures without judicial determination of contract termination.
Contract/Lease law – Renewal option and tacit continuation – Municipal by‑laws – Interim interdict – Urgency – Extra‑judicial termination prohibited; court must determine lawful termination.
28 June 2017
Plaintiff’s failure to discharge debts and cancelation of security prevented performance; no implied obligation to place DOCs existed.
Contract law — Implied terms — Whole-agreement clause; Grower’s obligations to order DOCs — Prevention of performance / mora debitoris — Anticipatory breach — Mitigation of loss — Counterclaim for interest and collection commission — Costs on higher (attorney/client) scale.
28 June 2017
Urgent application to stay eviction dismissed for lack of urgency and absence of locus standi.
Civil procedure — Urgent chamber application — urgency requirements; Locus standi — subtenant status and right to litigate where cession invalid; Eviction — effect of magistrate’s eviction order and inability to restore status quo after execution absent palpable miscarriage of justice; Estate administration — review available only to persons with direct legal interest.
21 June 2017
May 2017
An agreement of sale creates only personal rights; a judgment creditor's caveat prevails absent special circumstances.
Property law — agreement of sale vs registration — real rights in immovable property — judgment creditor’s caveat and judicial lien — upliftment of caveat requires special circumstances.
31 May 2017
Acquisition of agricultural land under section 72 by Gazette publication is valid; applicants failed to prove illegality or bias.
Constitutional and administrative law — Acquisition of agricultural land under s72 — Gazette publication suffices as notice — Land Acquisition Act s5 proviso — judicial review available for illegality, irrationality or procedural impropriety — compensation limited to prior improvements.
31 May 2017
Uncorroborated verbal agreements plus the written mandate sufficed to establish a prima facie case; absolution dismissed.
Civil procedure – absolution from the instance – prima facie case required; Interpretation of written mandate limiting commission; Alleged verbal agreement to vary written mandate – evidential sufficiency of uncorroborated testimony.
31 May 2017
Amendment allowed to correct trust-account error; mis-citation not fatal and prescription not shown to bar the claim.
Civil procedure – amendment of pleadings (Order 20 r 132) – mis-citation of rule not fatal – prescription (Prescription Act s 16) – debt due when creditor aware of debtor and facts – trust account; release of purchase money before transfer.
31 May 2017
Appellant failed to prove ownership in interpleader; acquisition included liabilities and appeal dismissed with costs.
Interpleader; onus on claimant to prove ownership of attached property; acquisition of business as going concern includes liabilities and trade name; imperfect citation/trading style; presumption goods at judgment debtor's address belong to debtor; costs on attorney-and-client scale for dishonest conduct
31 May 2017
Summary judgment refused because an innocent purchaser raised a bona fide defence and triable issues despite prior judgment.
Civil procedure – summary judgment (Rule 64) – requirement of no bona fide defence; Property law – double sales; innocent purchaser and indefeasible title; res litigiosa and effect of prior judgment; balance of equities.
31 May 2017
Single-incident domestic assault incorrectly charged under Domestic Violence Act; conviction substituted to ordinary assault and sentence reduced.
Criminal law — Charge framing under Domestic Violence Act — Correct citation of s 3(1)(a) read with s 4(1) — Domestic Violence Act intended for repeated/patterned abuse — Single-incident domestic violence may be ordinary assault — Substitution of conviction and sentence on review; mitigation where medical evidence absent.
31 May 2017
Failure to apply Road Traffic Act s64(3) and to establish negligence in plea rendered the sentence manifestly inadequate.
Road Traffic Act s64(3); culpable homicide arising from driving; plea proceedings—requirement to establish particulars and degree of negligence; mandatory licence cancellation and driving prohibition; sentencing review and remittal.
31 May 2017
Interest accrues on judgments silent on interest, but must be recovered by appropriate proceedings; existing writs cannot be used to seize for interest.
Prescribed Rate of Interest Act s 5 — interest on judgments silent on interest — interest accrues but recovery requires separate/court process; writ of execution only enforces what the judgment orders; agent liability absent fraud.
31 May 2017
Sentencing for culpable homicide balancing negligence, violence, guilty plea and first‑offender mitigation.
Culpable homicide; sentencing — balancing recklessness and brutality against guilty plea and first‑offender status; limited mitigation from intoxication or provocation.
30 May 2017
Summary judgment granted where debtor’s email acknowledged the debt and no proof of payment was produced.
Civil procedure — summary judgment — bona fide defence — acknowledgment of debt — interruption of prescription — condonation of procedural defect under r 4C — sufficiency of corporate citation as "body corporate".
26 May 2017
A convicted appellant was granted bail pending appeal after showing reasonable prospects of success and low abscondment risk.
Bail pending appeal – s 123 Crim. Proc. & Evid. Act – s 115C burden on convicted appellant to show interests of justice on balance of probabilities – prospects of success – credibility findings and misdirection – risk of abscondment; military service as tie to jurisdiction.
26 May 2017
Failure to comply with Order 40 requirements for objecting to a sheriff's sale defeats an application to set aside confirmation.
Execution — Sale in execution — Order 40 r 356, r 359 — Requirement to file timeous, competent objection to confirmation — Sheriff acts under writ and within rule‑book — Informal letters do not stay execution — Application must stand on founding affidavit.
25 May 2017
Court granted leave to execute against a company under provisional judicial management where execution would not defeat its purpose.
Companies Act s301(1) – provisional judicial management – stay of execution – court's discretion to grant leave to execute – balancing creditors' interests – enforcement against banks.
24 May 2017
Court finds purported sale to nephew a sham; awards plaintiff 35% of matrimonial stand and specific movable items.
Family law – Matrimonial property – Division on divorce under Matrimonial Causes Act s 7(4) – Sham/secret sale to third party to defeat spouse’s claim – Evidentiary burden to show lack of bona fides – Valuation and buy-out/sale mechanism.
24 May 2017
Customary shelter rights are personal, not real, so a purchaser may evict occupying family members; transfer cannot be set aside.
'Rei vindicatio' – ejectment – owner’s right to exclusive possession; customary law – Shona customary right to shelter – personal right v. real right; sale in execution – procedural objections and joinder; counterclaim irregularity; costs on attorney-and-client scale.
24 May 2017
Provisional spoliation order granted where school tuck‑shop lessee was unlawfully deprived of possession by added locks.
Property law — Spoliation — requirements of peaceful and undisturbed possession and unlawful deprivation; Commercial Premises (Rent) Regulations SI 676/1983 — definition of commercial premises; s 24 prohibition on self-help; s 22 notice requirements; provisional spoliation order granted.
24 May 2017
Urgent interdict to prevent filling CEO post refused for lack of urgency and existence of alternative remedies.
Urgent applications — criteria for urgency — irreparable prejudice — alternative remedies — employment law: suspension, withdrawal of disciplinary charges, purported termination — interim interdict to prevent appointment to office.
24 May 2017
Plaintiff's rei vindicatio succeeds; defendant's fraud claim unproven; eviction granted, holding-over damages denied.
Property law – rei vindicatio – proof of ownership and title – allegations of fraud in prior sale – innocent purchaser protection – eviction – holding-over damages not established.
24 May 2017
Applicant, in default proceedings, established entitlement to adultery damages (contumelia and loss of consortium) and was awarded US$8,000 with interest and ordinary costs.
Adultery damages — contumelia and loss of consortium — default judgment under Order 32 r 226(2)(d) — quantum factors (status, duration of marriage, deterrence, comparable awards) — costs: ordinary versus legal practitioner and client scale.
24 May 2017
Failure to pay for agreed services does not trigger arbitration; special plea dismissed and costs awarded to applicant.
Contract law – dispute resolution clauses – arbitration and mediation – whether non-payment constitutes a dispute requiring arbitration – court jurisdiction – abuse of process – contractual costs provision (legal practitioner and client).
22 May 2017
Registered owners' real rights prevail; untransferred purchaser has only personal contractual remedies against the seller.
Property law – rei vindicatio – registered ownership prevails over untransferred purchaser's personal contractual rights; remedy against seller for breach of contract; court may dismiss unopposed application where legal principles defeat claim.
22 May 2017
Interlocutory interdict granted to restrain farming on disputed land pending final determination; Land Commission does not oust High Court jurisdiction.
Interlocutory interdict — requirements (prima facie right, irreparable harm, absence of alternative remedy, balance of convenience) — lis alibi pendens — Land Commission jurisdiction does not oust High Court — boundary dispute — interim relief pending final determination.
22 May 2017
Application not urgent and spoliation not shown where goods were removed under a valid writ and interpleader remedy available.
'Urgency' – requirements for abridgement of court rules; Mandament van spolie – two requirements (peaceful possession and forcible/wrongful dispossession); Execution of writ – lawful execution negates spoliation; Interpleader proceedings (Order 30) as alternative remedy; Delay in instituting proceedings defeats urgency.
19 May 2017
Appellant failed to prove ownership; directors’ inter‑company conduct justified refusing to uphold interpleader claim and appeal was dismissed with costs.
Company law – separate legal personality – interpleader – ownership of assets – execution against judgment debtor – lifting the corporate veil – directors’ conflict and connivance – interim relief not definitive on ownership.
19 May 2017
Attempted murder conviction upheld; sentence found unduly lenient and review certificate withheld.
Criminal law – Attempted murder – Constructive intent (subjective foresight) – Actus reus and mens rea established by pouring boiling water – Sentencing review – Unduly lenient sentence – Review and withholding of certificate.
19 May 2017
Private association meetings are not subject to POSA public‑meeting permission; police may be notified but cannot prohibit them.
Public Order and Security Act – meaning of "public meeting" and "meeting" – private association meeting not a public meeting – police role limited to notification and security, not permission – unlawful interference with constitutional rights to assembly and association.
19 May 2017
A default judgment against one co-defendant does not extinguish the respondent’s claim against the other co-defendant.
Magistrates' Court — Default judgment — Order 11(4)(9) — Continuation against non-defaulting defendants; Functus officio — default judgment not final on merits; Stated case — Order 19 — admissions dispense with proof of quantum; Pleadings — liberal approach in magistrates' court; Stipulatio alteri — no vinculum juris without offer and acceptance; Costs — no attorney-and-client costs awarded.
18 May 2017
Delay without satisfactory explanation justifies dismissal under r 236(3); poverty and subsequent filings did not excuse default.
Rule 236(3) – dismissal for want of prosecution – good and sufficient cause – adequacy of explanation for delay (poverty not automatically excusable where legal representation remains) – relevance of prospects of success – inability to purge default without leave.
17 May 2017
Applicant holding the operating licence obtained a provisional interdict to restore licensed premises and restrain respondents' interference.
Administrative/licensing law – operating licence held by trading individual – locus standi – urgency – interim interdict: prima facie right, irreparable harm, absence of alternative remedy, balance of convenience – unlawful eviction and alteration of licensed premises.
17 May 2017
Court granted interim interdict to protect management rights and members’ subscription funds pending final determination.
Management agreement; interim interdict; urgency; Form 29B; prima facie right; irreparable harm; preservation of status quo; joinder where respondent controls disputed funds.
17 May 2017
Executor dative entitled to interim stay preventing confirmation of sale where validity of directors’ appointment and hypothecation is disputed.
Company law – validity of directors’ appointment – hypothecation of company property – executor dative’s locus standi – stay of execution pending declaratory action – urgency and interdictory relief to prevent confirmation of sale in execution.
17 May 2017
Urgent anti-dissipation relief dismissed for lack of urgency, absence of legal interest, material non-disclosure and abuse of process.
Practice — Urgency — requirements for certificate of urgency; Anti-dissipation interdict — need for prima facie evidence of likely dissipation; Interim relief — must differ in effect from final relief; Abuse of process and material non-disclosure; Costs — attorney and client scale.
17 May 2017
Court declined to dismiss a stay application for want of prosecution, preserving a substantive rescission/joinder challenge for hearing.
Civil procedure – Dismissal for want of prosecution – r 236(3) High Court Rules – Court’s discretion – Delay and immediate filing after notice – Procedural irregularity/default judgment – Interrogation under r 449 – Costs in the cause.
17 May 2017
Claimant failed to prove ownership of an attached vehicle; appeal dismissed for lack of merit.
Civil procedure — interpleader — proof of ownership on balance of probabilities — authenticity and alteration of documentary evidence — attachment in execution — possible collusion — costs.
17 May 2017