Harare High Court - 2022 November

86 judgments
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86 judgments
Citation
Judgment date
November 2022
Registered owner entitled to evict occupier who fails to prove payment or entitlement to co-ownership.
Property law – actio rei vindicatio – registered title – burden of proof on balance of probabilities – claim for co-ownership via contribution – registration in Deeds Registry conveys real rights – eviction remedy.
30 November 2022
Belief in witchcraft is not a defence to murder; provocation requires sudden loss of self-control — convicted and sentenced to 35 years.
Criminal law — Murder — Intention to kill; Provocation — Witchcraft belief not a defence but mitigatory (s101); Provocation requirements (s239) — sudden loss of self-control and no cooling-off; Premeditation and multiple murders as aggravating factors; Late-raised non-pathological criminal incapacity unsupported.
30 November 2022
High Court set aside a magistrate's cancellation of the respondent's arrest warrant for gross procedural irregularities.
High Court — s 29(4) mero motu review; judicial assistance by counsel — Magistrate procedure — Default enquiry and cancellation of warrant — Functus officio — Gross irregularity and illegality — Judicial independence — Fugitive from justice and dirty hands doctrine — Review and setting aside of proceedings.
30 November 2022
Confirmed warned‑and‑cautioned statement admissible; both accused convicted of murder and sentenced to 25 years imprisonment.
Criminal law – Murder – Admissibility of confirmed warned and cautioned statement – Confirmation proceedings – Use of extra‑curial confession against co‑accused – Circumstantial evidence and alibi – Aggravating circumstances (robbery, premeditation) – Sentencing under s 47 Code.
28 November 2022
26 November 2022
Recent possession and reliable identification supported convictions for multiple aggravated robberies; sentence upheld as appropriate.
Criminal law – Robbery (s 126) – aggravated circumstances – use of weapons and serious violence; Identification evidence – identification parade reliability; Recent possession of stolen property as evidential link to robbery; Sentencing – judicial exercise of discretion, deterrence and proportionality in aggravated robberies.
25 November 2022
A tacit acknowledgment via draft and email established a binding US$ debt; judgment for US$ amount or ZWL$ equivalent, interest and costs.
Acknowledgment of debt – tacit and express acknowledgment – requirements and proof; Currency of obligation – US$ versus ZWL$ – enforceability of US$ obligations post-February 2019; Conversion – use of prevailing foreign currency auction rate; Credibility of witnesses and weight of correspondence as evidence of agreement
24 November 2022
A sale of shares by a non‑owner is void; the Contractual Penalties Act did not apply and the declaratory claim was dismissed.
Company law – sale of shares – seller without title – nemo dat quod non habet; Contractual Penalties Act inapplicable to share sales; separate corporate personality – veil not pierced
24 November 2022
Admissible confirmed confession corroborated by evidence; accused convicted of premeditated robbery-murder and sentenced to 25 years.
Criminal law – murder – admissibility of confirmed warned and cautioned statement (s256) – right to silence and adverse inferences (ss189(2),199) – conviction on confession corroborated by independent evidence (s273) – murder in course of robbery and premeditation – sentencing (s47).
24 November 2022
Condonation for a 14-month-late review application refused for unreasonable delay and poor prospects of success.
Administrative law – condonation for non-compliance – factors: degree of delay, explanation, prospects of success; misjoinder not fatal; natural justice – opportunity to cross-examine; internal military appeal procedures
23 November 2022
Applicant failed to prove respondents were serial litigants; perpetual silence decree refused and costs awarded on legal practitioner and client scale.
Civil procedure — Decree of perpetual silence; vexatious/serial litigant; abuse of court process; access to courts; requirement of particularised evidence; punitive costs (legal practitioner and client)
23 November 2022
Court granted condonation to file review over arguable town-planning notice and publication irregularities, finding reasonable delay and prospects of success.
Procedure – Condonation for late noting of review – Factors: extent of delay, explanation, prospects of success, prejudice, finality and convenience – Town planning – Regional Town and Country Planning Act s 26(3)(4) – Publication requirements (newspaper versus Government Gazette) – Service of notice by registered post – Judicial discretion to do justice
23 November 2022
High Court dismissed review: no exceptional grounds to overturn magistrate's refusal to discharge at close of State case.
Criminal procedure — Review of unterminated proceedings — Exceptional circumstances required; Discharge at close of State case (s198(3)) — Affidavit as prima facie evidence and burden shift on disputed authorship; Amendment of charge (s202); Effect of repeal on offences — savings under Interpretation Act s17; Prima facie standard versus proof beyond reasonable doubt
23 November 2022
Application for division of inherited land dismissed after founding affidavit expunged for inconsistent notarization; costs on attorney and client scale.
Actio communi dividendo – testamentary division of property – founding affidavit irregularity – inconsistent notarization – expungement – absence of application – dismissal – costs on attorney and client scale
23 November 2022
Combined condonation and rescission application dismissed for inordinate delay and unacceptable poverty explanation.
Civil procedure — Default judgment — Combined application for condonation and rescission under r 27 — Combined procedure permissible; absence of plea or extension not fatal; lawyer affidavit acceptable — Delay of 14 months and poverty explanation insufficient for condonation — rescission refused.
23 November 2022
Trial courts erred by imposing restitution as a direct sentence without statutory basis or required application.
Criminal procedure — Restitution not a sentence — Suspension of sentence s 358(2)(b) — Part XIX compensation and restitution — s 368 requirement of application — Competency of restitution orders.
23 November 2022
Accused 1 acquitted: fatal blow found lawful defence of person under s 253; accused 2 properly placed on defence.
Criminal law — Defence of person (s 253) — Requirements: unlawful attack, imminence, necessity, inability to escape, reasonable means, proportionality — Credibility of witnesses — Discharge at close of State case (s 198(3)) — Common purpose.
23 November 2022
Conviction for murder where a magistrate‑confirmed confession, corroborated by independent evidence, proved guilt beyond reasonable doubt.
Criminal law – murder – admissibility of warned and cautioned statements – s256 CP&E Act – conviction on confession – s273 CP&E Act requiring independent corroborative evidence – s314 admissions – voluntariness and corroboration of confession; domestic violence context.
23 November 2022
Sentence for culpable homicide set aside due to sentencing irregularities; conviction upheld despite defective charge.
Criminal law – culpable homicide (s 49) – charge drafting – distinction from road traffic offences – sentencing – inquiry into degree of negligence – s 64(3) Road Traffic Act – suspended sentence conditions – irregular sentence set aside – remittal for re-sentencing.
23 November 2022
An urgent application relying on a certificate of urgency that predates the founding affidavit is fatally defective and dismissed.
Spoliation (mandament van spolie) – urgent chamber application – certificate of urgency requirements – certifier must have read and applied mind to founding affidavit – certificate predating founding affidavit invalidates urgency – impropriety of certifier employed by applicant’s law firm
22 November 2022
Failure to notify affected persons per s124(2)(b) of the Insolvency Act renders a corporate rescue application nullity.
Insolvency Act s124(2) — corporate rescue — peremptory "standard notice" requirement (registered mail, fax, e-mail or personal delivery) — affected persons defined — retrospective service ineffective — locus standi/affected person and shareholding issues reserved for merits
22 November 2022
Applicant granted leave to execute pending appeal due to prejudice and weak prospects of appeal.
Execution pending appeal — factors: irreparable harm, balance of convenience, prospects of success; forfeiture vs seizure for prescription under Customs and Excise Act; arbitrary administrative decision; costs on ordinary scale
22 November 2022
Accused acquitted of murder after court finds self-defence requirements satisfied and State failed to prove intent to kill.
Criminal law - murder - defence of person (self-defence) - s 252/253 Criminal Law (Codification and Reform) Act - requirements: unlawful attack, necessity, impossibility of escape, reasonableness of force - intoxication and causation of death - insufficiency of State's proof.
22 November 2022
A seven-year unexplained delay and weak appeal grounds meant condonation and leave to prosecute in person were refused.
Criminal appeal — Condonation for late noting — length of delay, adequacy of explanation, prospects of success; identification parade — absence not automatically fatal; dock identification; recovery of stolen property; sentence proportionality.
22 November 2022
22 November 2022
Court upheld trial sentence, noting questionable use of Domestic Violence charge but no basis to disturb sentencing discretion.
Criminal law — Domestic Violence Act v ordinary assault — appropriateness of charging; sentencing — use of weapon, blows to the head, elderly victim — appellate review of alleged lenient sentence.
21 November 2022
Civil claim dismissed as prescribed; later criminal restitution did not revive the plaintiff's right to sue.
Prescription – cause of action arising from prior civil judgment – three-year prescription period; interruption by acknowledgment of liability – effect of criminal restitution on civil prescription; competence of claim where agreement void ab initio; unjust enrichment
18 November 2022
Mandament van spolie denied where occupier remained in possession; no contempt; interdiction against construction pending eviction.
Property law – mandament van spolie – requirement of actual dispossession; Status quo interim order – contempt requires wilful disobedience; Interdicts pending eviction proceedings; Costs — attorney-client costs reserved for abuse of process.
18 November 2022
Accused found not guilty by reason of insanity; court orders transfer to psychiatric unit as non-custodial placement unavailable for serious offence.
Criminal law — Insanity verdict under Mental Health Act s29(2) — psychiatric evidence — dispositional options for serious offences — placement with relatives limited to non-serious offences — return to prison for transfer to psychiatric institution.
18 November 2022
s29(2) requires trial evidence, including expert medical proof, to return a not-guilty-by-insanity verdict.
Mental Health Act ss 28 and 29(2) – insanity defence – special verdict of not guilty because of insanity – requirement that s29(2) be satisfied from evidence at trial, including medical expert evidence – distinguishing unfitness to stand trial (s28) from insanity at time of offence (s29(2)) – disposition by committal for treatment.
18 November 2022
Whether tax officers may seize computers absent statutory authorization and whether a corporate deponent must produce board authorisation.
Corporate representation — requirement for board resolution when authority is challenged; Spoliation — mandament van spolie; Tax statutes — powers to seize documents/printouts but not computers; Ejusdem generis
17 November 2022
Appellant’s robbery conviction and effective custodial sentence upheld; non-recovery of firearm and new allegations on appeal insufficient to succeed.
Criminal law – Robbery – Use of firearm – Aggravating circumstances under s126(3)(a),(b) – Non-recovery of weapon does not invalidate conviction – Appeals: fresh allegations raised on appeal inadmissible without prior trial evidence; credibility findings not disturbed absent clear misdirection.
17 November 2022
Application to file an additional affidavit recording an AGM ratification refused as it would materially alter the pleaded causa and prejudice applicant.
Civil procedure – Motion proceedings – Rule 59(12) – Leave to file additional affidavits – Discretionary relief – Requirements: absence of mala fides, valid reason for lateness, no prejudice, and no material alteration of causa – Res litigiosa – Post‑pleading AGM ratification not permitted to alter pleaded cause
16 November 2022
Court removed divorce trial from roll and ordered the joined trust to file appearance and plea within 10 days.
Civil procedure — Joinder of party already ordered — Failure to enter appearance and plead — Removal from roll and case-management directions to complete pleadings
16 November 2022
Court suspended execution pending rescission, permitting limited occupation while preserving respondents' interdiction against interference.
Stay of execution pending rescission — discretionary exercise guided by real and substantial justice — default judgment — improvement lien v. real rights under offer letter — non-joinder of Sheriff not fatal — interim limited occupation permitted
16 November 2022
Applicant entitled to declaratory relief affirming prior pegging rights; later registrant’s certificate void and mining unlawful.
Mining law — Declaratory relief — Prior pegger’s rights and priority (s31(1)(b); s177(3)) — Effect of registration and reservation against prospecting — Certificate of registration declared null and void — Lis pendens and dispute of fact points dismissed
16 November 2022
Plaintiff adduced a prima facie malicious prosecution claim; absolution from the instance was dismissed pending defendant’s case.
Civil procedure — absolution from the instance — prima facie case test; Malicious prosecution — elements: instigation, want of reasonable and probable cause, malice, failure of prosecution; court must assume plaintiff’s evidence true unless inherently unacceptable
16 November 2022
Issue estoppel barred the applicant’s interdict to restrain sale of disputed land; application dismissed with costs.
Civil procedure — Res judicata / issue estoppel — Effect of matter struck off the roll for failure to regularise defects — Deemed abandonment after unsuccessful appeal — Interdict to restrain transfer of property barred
16 November 2022
Applicant with original title deed obtained interim interdict to halt transfer of disputed property pending ownership determination.
Deceased estates — Interim interdict pending action — Urgency — Locus standi to challenge transfer — Prima facie right to property despite registered title (rebuttable presumption) — Irreparable harm and no alternative remedy — Balance of convenience
16 November 2022
Applicant entitled to declaratur of title over converted gold blocks; 1st respondent’s registration held null and void.
Mining law — Declaratory relief — Title to mining claims — Forfeiture — Conversion of base block into three gold blocks — Deference to Ministry records — Material disputes of fact and exhaustion of administrative remedies
16 November 2022
Court suspended sale of a jointly owned family home where hardship, a viable alternative sale of an executable machine, and estate interests prevailed.
Civil procedure – Rule 71(14) & (18) – suspension/postponement of sale in execution of a dwelling occupied by debtor/family – "great hardship" test; Execution law – sheriff's return and proof of forfeiture; Property law – joint ownership and deceased co‑owner's estate rights; Burden to rebut sheriff's return
16 November 2022
A sale and transfer founded on a fraudulently procured executor appointment is void; title must be restored to the estate.
Succession law — Executor dative appointed by fraud — Appointment void ab initio — Sale and transfer founded on fraud nullified — Innocent purchaser defence limited where transaction tainted — Registrar ordered to revive prior title — Eviction authorized — Costs on attorney and client scale
16 November 2022
Joint registration of residential property confers equal 50% shares; no tacit universal partnership established, defendant must sign subdivision and pay half costs.
Property law — Tacit universal partnership — Requirements: contributions, joint business for profit and legitimate partnership — Registration in joint names confers equal real rights enforceable against the world — Stated case (r 52) binds court to agreed facts.
16 November 2022
Declaratory relief challenging a fraudulent transfer of immovable property not prescribed; transfer set aside; conveyancer not liable.
Property law – Fraudulent transfer and cancellation of title deed – Forgery and false identity particulars – Prescription: section 16(3) Prescription Act – Declaratory relief not barred by prescription – Estoppel in property transfers – Conveyancer's due diligence and non-joinder.
16 November 2022
A point of law that an opposing affidavit was improperly commissioned can be raised anytime; defect remediable, respondents ordered to amend.
Civil procedure – validity of affidavits – improper commissioning where commissioner’s endorsed date of administration absent – point of law may be raised at any time – remediable defect – matter removed from roll and respondents ordered to amend affidavit.
16 November 2022
Summary judgment upheld where defendant failed to show a bona fide prima facie defence of purchase through an alleged agent.
Civil procedure – Summary judgment – extraordinary remedy; defendant must show bona fide prima facie defence; proof of agency and concluded sale required; failure to produce cession/title documents fatal; attorney-and-client costs for abuse of process.
16 November 2022
Rule 62(4) requires an application for extension of time as well as condonation for late review proceedings.
Civil procedure — Review — SI 202/21 r 62(4) — requirement to seek extension of time for late review applications (good cause shown) in addition to condonation; Administration of Estates Act — s116/internal remedies — inquiry into executor; revival of superannuated orders.
16 November 2022
Apparent authority of managing director bound the company; both defendants held jointly liable for undelivered vehicles.
Agency and company law – ostensible/ apparent authority of managing director – estoppel – company bound by acts and representations of its officers; specific performance and alternative damages; joint and several liability; conduct after separation as factor in personal liability.
16 November 2022
Landlord proved rent arrears; High Court set aside absolution and ordered eviction, arrears, holding-over damages, licence surrender and costs.
Eviction — Landlord-tenant — Non-payment of rent — Burden and standard of proof in civil eviction proceedings — Absolution from the instance (Magistrates' Court Act s18) — High Court jurisdiction (Civil v Commercial Division) — Holding-over damages — Surrender of regulatory licence.
16 November 2022
Appeal upheld: magistrate had jurisdiction over spoliation, but material disputes of fact and lapse of time made the spoliation order unsustainable.
Civil procedure — Mandament van spolie — Jurisdiction of Magistrates Court — Possession v ownership — Disputes of fact in spoliation proceedings — Lapse of time and implied consent as defence — Condonation for late filing of heads of argument.
16 November 2022