Harare High Court - 2023 February

56 judgments
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56 judgments
Citation
Judgment date
February 2023
28 February 2023
Leave of court was required before suing a company under provisional judicial management; plaintiff failed to obtain it.
Companies Act s301(1) – provisional judicial management – requirement for leave to sue – stay of proceedings – protection of company assets and rehabilitation – sureties and co-principal debtors – prescription abandoned – exchange control raised but not determined.
23 February 2023
Residents' association granted urgent interim interdict halting re-pegging and collection of money pending determination.
Urgent interim interdict; locus standi of residents' association; High Court competent to grant interlocutory relief despite administrative remedies; land repegging, double allocations, and unlawful collection of funds; prima facie right and irreparable harm established.
23 February 2023
Rescission refused where applicant failed to prove non‑service, provide a reasonable excuse, or show a bona fide defence.
Civil procedure — Rescission of default judgment (Rule 27 High Court Rules 2021) — Proper service by placing documents in letter box and by personal service — Requirement of reasonable explanation and bona fide defence with prospects of success.
23 February 2023
Failure to file the paginated indexed bundle required by rule 12(2) rendered the defendants' exception defective and it was dismissed.
Civil procedure – Commercial Court Rules – rule 12(2) requirement for a paginated and indexed bundle supporting pleas/exceptions – non‑compliance renders exception defective – interlocutory procedure and costs for mutual non‑compliance.
23 February 2023
Court refused to review magistrate’s refusal to discharge accused, finding prima facie extortion evidence and no exceptional grounds to interfere.
Criminal procedure — discharge at close of State case (s 198(3)) — three‑pronged test: elements of offence, whether reasonable court might convict, manifest unreliability of State evidence — prima facie case of extortion established by testimonial and documentary evidence (Ecocash and bank records) — reluctance to interfere with uncompleted trials absent exceptional circumstances.
23 February 2023
Application for condonation and leave to appeal refused due to inordinate delay and dim prospects of success on conviction and sentence.
Condonation of late noting of appeal — factors: degree of non-compliance, reasonable explanation, prospects of success — medical report in sexual offence cases — s 278(3a) Criminal Procedure and Evidence Act — credibility findings and appellate restraint — sentence within comparative range for rape.
23 February 2023
A former owner divested by a Supreme Court judgment lacks locus standi to cancel a subsequent transfer; miscitation/non-joinder is fatal and costs awarded.
Locus standi – former owner divested by prior judgment lacks direct and substantial interest to challenge subsequent registration; Non-joinder/miscitation – Sheriff must be correctly cited where his acts are impugned; Civil procedure – locus standi and no-joinder are matters for special plea, not exception; Deeds Registries Act s8 – cancellation applications require a recognisable legal interest; Costs – wasted costs on higher scale for frivolous recusal attempt.
22 February 2023
Whether an exception was properly taken and whether omission of communication element renders an incitement charge incurably defective.
Criminal procedure — Exception to charge — Proper statutory route under CPEA (ss 170, 171, 178, 180) — Incitement (s187) — Essential element of communication — Defective charge — Review of unterminated proceedings — When High Court should set aside proceedings.
22 February 2023
Cooperative allocation and partnership rights prevailed; respondent lacked locus standi to evict due to defective/irregular lease.
Property law – State land allocation and double allocations – Cooperative allocations under Partnership Agreement with Apex Board and Ministry – Regularity of leases – Locus standi to bring rei vindicatio – Occupation and rights flowing from cooperative allocations.
20 February 2023
Bail pending appeal denied where appeal lacked reasonable prospects, sentence not manifestly excessive, and risk of absconding was heightened.
Bail pending appeal – criminal abuse of duty (s 174) – reasonable prospects of success – intention inferred from conduct – sentencing discretion – custodial sentence justified – risk of absconding.
20 February 2023
Application to cancel competing title deeds dismissed due to unresolved material disputes of fact requiring oral evidence.
Property law – competing title deeds – application for declaratur to cancel deeds and replace title; Civil procedure – service of process and compliance with High Court Rules; Prescription – requirement to plead with particularity; Motion proceedings v trial – material disputes of fact requiring viva voce evidence; Conveyancing irregularities and Registrar of Deeds queries.
20 February 2023
Specific performance granted where plaintiff proved purchase, payment, and long possession; defendant failed to prove forgery.
Specific performance – sale of immovable property – proof of contract, payment and possession – credibility of witnesses – burden to prove alleged fraud/forgery.
20 February 2023
Accused acquitted of murder but convicted of culpable homicide for negligent strangulation causing death.
Criminal law – Homicide – Distinguishing murder from culpable homicide – Intention to kill versus negligence/recklessness; post‑mortem evidence; acceptance of limited plea under s 49 Criminal Law (Codification and Reform) Act [Chapter 9:23].
17 February 2023
Condonation granted where delayed record and procedural defects (failure to put firearm charge, poor credibility analysis) give reasonable prospects of success.
Condonation of late noting of appeal; delay due to missing/delayed record; prospects of success; failure to put charge to accused; deficient trial judgment for lack of credibility appraisal; extension of time; leave to appeal in person.
17 February 2023
Whether declaratory relief should set aside a valid expulsion notice after applicant failed to make timely representations.
Refugee law — Expulsion under s 15 Refugees Act — Service of notice and 14-day right to make representations — Declaratory relief v. review — Court’s discretionary power to grant a declaratur — Procedural fairness and condonation not determined.
16 February 2023
Appeal against conviction and sentence for theft of entrusted cash dismissed; trial court’s findings and deterrent sentence upheld.
Criminal law – Theft of trust property – Standard of appellate review of factual findings – Custody and access to cash box keys – Documentary evidence and credibility – Sentencing: abuse of trust, substantial loss, deterrence, suspension conditional on restitution.
16 February 2023
Appellate court upheld rape conviction and 15-year sentence; complainant credible and reporting delay excused.
Criminal law – Rape – Credibility and corroboration – Delay in reporting – Discrepancies immaterial – Abuse of position of trust – Sentence not excessive.
16 February 2023
Condonation for late appeal refused because proposed grounds lack reasonable prospects of success on conviction and sentence.
Criminal procedure – Condonation for late noting of appeal – factors to consider (degree and explanation of delay, prospects of success, finality) – COVID‑19 as explanatory factor – Appeal on conviction: identity of accused – corroborative child evidence and medical report – Sentence review: proportionality for rape of minor.
16 February 2023
Misjoinder in contempt proceedings is fatal; contempt requires a clear order, awareness and willful disobedience.
Contempt of court – requirements: clear and unambiguous order; awareness; willful disobedience – Misjoinder/non‑joinder fatal in contempt applications – Validity and presumption of court orders until set aside.
15 February 2023
Applicant with an unrevoked lease-to-buy declared lawful holder and granted ejectment against respondent occupying the stand.
Property law – lease-to-buy – locus standi to seek declarator and ejectment – proof of title and cooperative allocations – resolution of disputes on motion papers.
15 February 2023
Failure to obtain written consent under s31 does not automatically void a mining registration; wrong remedy pursued.
Mines and Minerals Act s31 — landholder's written consent for prospecting — failure to obtain consent does not ipso facto nullify mining registration; appropriate remedy is interdict/compel compliance, not automatic cancellation.
15 February 2023
Beneficiary lacked standing to seek a s14 declaratur nullifying a deceased's marriage; review of Master/executor was the proper route.
Civil procedure — locus standi to challenge validity of marriage post mortem; declaratory relief under s14 High Court Act in relation to deceased estates; proper procedure is review of Master's/executor's decisions; mootness of claims affecting deceased persons; non-joinder not necessarily fatal but dispositive preliminary points may strike matter off roll.
15 February 2023
Conversion of the applicants' USD bank balance to RTGS was ultra vires and violated their constitutional property rights.
Exchange control — Directive RT120/2018 — paras 2.5 & 2.6 ultra vires s 35(1) — unlawful conversion of USD bank balances to RTGS — deprivation of property (s 71) — certain Finance (No.2) Act provisions invalid — remedial repayment in USD with interest — declarations subject to s175(1) confirmation.
15 February 2023
Bail refused for accused charged with raping his minor daughter due to flight risk and likely witness interference.
Bail pending trial — rape of a minor — flight risk — likelihood of interfering with state witnesses — familial relationship heightening interference risk — seriousness of offence.
15 February 2023
Association lacked authority under its constitution to sue without a General Meeting resolution; application dismissed with costs.
Associations — constitutional powers of management committee — locus standi to sue — literal interpretation of constitution — expressio unius — purposive interpretation inapplicable where language is clear — application dismissed for lack of authority to litigate.
15 February 2023
Court set aside default judgment where pending joinder made confirmation erroneously granted in applicant's absence.
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15 February 2023
14 February 2023
Applicants charged with serial aggravated robbery denied bail due to strong evidence, propensity to reoffend and statutory reverse onus.
Bail — distinction between remand and bail proceedings — challenge to reasonable suspicion inadmissible in bail application after acquiescence to remand facts; Bail — s50(1)(d) Constitution; s117 and s115C CP&E Act; Third Schedule reverse onus for Part I offences; Propensity and danger to public; Identification evidence and strength of State's case; Equality before the law — unequal treatment permissible where circumstances differ.
14 February 2023
Application to sell assets under a repealed Companies Act provision dismissed for lack of accrued right.
Companies law — repeal of statute — effect on accrued rights (Interpretation Act s17(1)(b)); judicial management — disposal of company assets; s307 Companies Act (repealed) required court leave; recovery of judicial management fees linked to insolvency law.
13 February 2023
Bail pending appeal denied where bribery conviction and negligible prospects of success made continued detention necessary for justice.
Criminal law – Bribery – Offer of bribe completes offence even if rejected – Bail pending appeal – factors: liberty, delay, prospects of success, risk of absconding – sentencing discretion and deterrence in corruption cases – prosecutor’s concession not binding on sentencing court.
13 February 2023
Executor may set aside an estate property sale made without the Master’s consent; costs awarded for abusive, meritless opposition.
Deceased estates — disposal of estate property without Master’s approval — nullity ab initio; executor’s locus standi to challenge unlawful disposal; Prescription Act inapplicable to void disposals; abuse of process and awarding of attorney-and-client costs; reversal of transfer and cancellation of title deed; surrender of deed and eviction order.
10 February 2023
Accused acquitted: statutory defence of person (self-defence) satisfied; State failed to disprove beyond reasonable doubt.
Criminal law — Defence of person (self-defence) under s 253 Criminal Law Code — Requirements for complete defence; Reasonable force and proportionality; Defence of property; Right to life (Constitution ss 86 & 48) and potential tension with statutory defences; Onus on State to negative self-defence.
10 February 2023
Convictions for theft of trust property set aside where charges and evidence failed to establish the terms of the trust or intention to misappropriate.
Criminal law – theft of trust property (s 112–113) – need to establish precise terms of obligation; debtor‑creditor/fungible‑money exception; proof of intention to misappropriate. Criminal law – corporate liability (s 277) – presumptions and need for proper pleading attributing conduct and intent to directors/employees.
10 February 2023
Applicant failed to prove an unregistered customary union; Master’s refusal to recognise a surviving spouse was upheld.
Administration of Estates Act s68G/s68J – unregistered customary marriage – proof required: roora/lobola and participation/corroboration by both families – weight of partisan affidavits – inquiry under Master of High Court.
9 February 2023
Stay granted pending rescission where default judgment was irregularly obtained and not served on the applicants.
Civil procedure – stay of execution – default judgment – defective barring procedure – service of judgment affecting status – High Court Rules 2021 r 42 and r 43 – irregular proceedings – urgency and balance of convenience.
9 February 2023
Conviction for infant rape quashed where witness inconsistencies and unresolved medical evidence raised reasonable doubt.
Criminal appeal – alleged rape of infant – contradictions between State outline and witness testimony; medical report ambiguous on penetration; failure to call examining doctor; reasonable doubt; appellate interference with credibility and factual findings.
9 February 2023
Medical and witness evidence supported attempted murder; sentence reduced for excess and youth, conviction upheld.
Criminal law - Attempted murder - Evidence of intention to kill from weapons used, injuries and medical reports - Sentence review - appellate interference limited but can reduce excessive sentence - consideration of youth and role - judicial decorum and language.
9 February 2023
Convictions quashed where prosecution failed to prove ownership, link to accused, and relied on inadmissible evidence.
Criminal law — Theft — failure to prove ownership/possession and link to accused; general‑deficiency allegations require production of audit/asset records (best evidence). Admissibility — extra‑curial admissions inadmissible without proof of voluntariness (s 256 CPEA). Translation — exhibits in vernacular must be translated into English. Insufficient evidence — acquittal warranted where prosecution reliance on inadmissible evidence and lack of recoveries/CCTV.
9 February 2023
Rescission application struck off for being filed out of time without condonation and based on inconsistent affidavits.
Civil procedure — Rescission of default judgment — High Court Rules r27 (one-month time limit) — condonation required for late rescission — misfiling of court papers and credibility of founding affidavit.
8 February 2023
A respondent may challenge contract validity in opposing a declaratory claim; absence of consensus and price voids the sale agreement.
Contract law — contractual interpretation and context — declaratory relief — respondent may challenge validity in opposing affidavit — consensus ad idem essential — price (pretium) ascertainability — non-variation clause and parol evidence.
8 February 2023
Applicant cannot compel transfer where land allocations were nullities due to statutory non-compliance and officials exceeded authority.
Administrative law – validity of municipal land allocations – non-compliance with Regional Town and Country Planning Act ss 49(2),(3) and s 39 and Urban Councils Act s 152(2) – acts of Town Clerk/Director beyond mandate – nullity of transaction – binding effect of Supreme Court ruling SC 1/23.
8 February 2023
Applicant's delay rendered urgent relief unnecessary; court dismissed attempt to restrain a lawfully completed sale in execution.
Civil procedure — urgency — stay of execution — interdict against sheriff — sale in execution — overtaken by events — applicant's delay — service after sale.
8 February 2023
Unavailability of counsel of choice alone does not justify postponement where it would unduly delay a criminal trial.
Criminal procedure — application for postponement — unavailability of counsel of choice — balancing accused's right to representation and speedy trial with public interest in expeditious proceedings — s 166(1) CPE Act; non-availability of counsel not ordinarily decisive.
8 February 2023
Court granted final interdict restraining the respondent’s defamatory social-media allegations of contaminated fuel and struck out an improperly authenticated affidavit.
Defamation; final interdict; social media publications; urgency; authentication of foreign affidavits (r 85 High Court Rules); striking out improperly authenticated evidence; costs on scale of legal practitioner and client.
7 February 2023
Employment contract disputes fall within the Labour Court's exclusive jurisdiction; an undated affidavit was not fatal.
Labour law – exclusive first-instance jurisdiction of the Labour Court over employment/termination disputes; civil procedure – affidavit formalities (undated affidavit not necessarily fatal).
7 February 2023
The employer is liable under rules 46 and 47 to reimburse the fund and pay pensions until the beneficiary is sixty-five.
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6 February 2023
Rescission refused where applicants delayed nine years after knowledge and conduct amounted to abuse of process; punitive costs awarded.
Civil procedure – Rescission of default judgment – Rule 449(1)(a) – requirements (erroneously sought/granted; absence; affected rights) – inordinate delay – abuse of process – punitive costs (attorney and client scale).
6 February 2023
Court lacked jurisdiction to review an acquisition absent alleged procedural non‑compliance with s16B(2)(a).
Land reform – s16B(2)(a) and s16B(3) ouster clause – jurisdiction to review acquisition confined to procedural non‑compliance on the face of the record – indigenous ownership not a basis to vitiate Schedule 7 acquisitions – s295 compensation framework.
3 February 2023
Interim interdict granted to protect the applicant’s prima facie mining title and prevent irreparable removal of ore.
Urgent chamber application; interim interdict to protect mining title; certificate of registration as prima facie proof of title; irreparable harm from removal of ore; balance of convenience; lis pendens and res judicata objections considered and dismissed.
3 February 2023