Harare High Court - 2025 June

50 judgments
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50 judgments
Citation
Judgment date
June 2025
Carrier’s strict liability for lost bullion upheld; vis major not proved, reconventional USD claim dismissed.
Carrier liability – Praetor’s Edict (nautis, cauponibus et stabulariis) – strict liability for loss in transit; vis major/casus fortuitus defence – onus and standard for supervening impossibility; negligence and collusion allegations – need for evidence; subrogation/res inter alios actae – requirements; currency of invoices – USD invoicing with ZWL payment alternative
30 June 2025
Appointment of a trustee and amendment of a trust deed done outside the deed’s procedures and without beneficiaries’ consent are invalid; interdict and punitive costs ordered.
Trust law – Trustee powers and fiduciary duties; Appointment and removal of trustees – interpretation of trust deed (specific v general clauses); Amendment of trust deed – beneficiaries’ consent and trust objects; Letters of wishes – non-binding guidance; Interdict to protect beneficiaries’ interests; Costs — punitive scale for conduct frustrating court orders
30 June 2025
Stay of execution granted for specified attached farming equipment pending rescission; company existence and dirty‑hands objections dismissed.
Civil procedure – stay of execution pending rescission of default judgment – prospects of success and balance of convenience required; attachment of goods in possession of claimant gives presumption of ownership; proof of company existence by re‑registration certificate; doctrine of dirty hands requires cogent evidence of contempt or misuse of attached goods
27 June 2025
Revival granted where a consent order provided an ascertainable method to calculate the outstanding judgment debt despite no stated figure.
Civil procedure – Revival of superannuated judgment – Consent order providing method to calculate monetary obligation – Requirement that judgment specify amount satisfied by ascertainable formula – Informal indulgences do not effect lawful variation of court order – Revival granted
27 June 2025
Owner’s rei vindicatio succeeds where occupier contracted with an unauthorized person; no apparent agency or estoppel, eviction ordered.
Property law – rei vindicatio – owner’s prima facie right; agency – actual and apparent (ostensible) authority; estoppel by representation; constitutional protection from arbitrary eviction (s74) – application in commercial occupation; perpetual land-use agreement; burden of proof in vindicatory actions
27 June 2025
Applicants granted condonation to bring a rescission under rule 29 after delay, given explanation and prospects of success due to procedural defects in consent order.
Civil procedure — Rescission of judgment by consent — Rule 449 (repealed)/Rule 29 — Condonation for delay required where rescission is not brought promptly — Prospects of success and procedural non-compliance with Rule 54 (consent orders) relevant to rescission applications — Costs in the cause.
27 June 2025
Plaintiffs proved title but failed to prima facie prove defendants’ trespass; absolution granted for want of evidence.
Property law — Mining claims — Ejectment/trespass — Prima facie proof of occupation — Necessity of survey/expert evidence to locate workings — Absolution from the instance where essential elements unproved — Non-joinder of adjacent claim-holder noted but not fatal
26 June 2025
Summons struck off for failing to disclose a cause of action after the plaintiff conceded the exception.
Civil procedure — Exception: vagueness and embarrassment — Failure to disclose a cause of action — Admission/concession and withdrawal — Amendment post-strike out — Arbitration clause and illegality raised but not decided — Claim struck off roll with costs
26 June 2025
Applicant failed to show that post‑1985 statutory changes or alleged non‑disclosure invalidated earlier customary‑law estate administrations.
Succession and estates — law applicable at death — custom versus general law (African Marriages Act s13) — non‑retrospectivity of Administration of Estates Act s68G — intestacy under customary law — evidential burden to impeach prior estate administration
26 June 2025
26 June 2025
Magistrate's failure to canvass statutory exceptions before departing from mandatory RTA sentence necessitated re-sentencing.
Road Traffic Act (s6(5), s6(6), s88A) — qualified mandatory sentences and lifetime driving prohibitions — burden on accused to prove statutory exceptions or 'special reasons' — duty of trial court to explain mandatory penalty and elicit evidence — procedural fairness in sentencing — High Court review power under s29(2)(b)(iii) to set aside unlawful sentences.
26 June 2025
Rescission refused: applicant failed to prove error; registered owner’s title upheld; punitive costs awarded.
Civil procedure – rescission under rule 29(1)(a) – consent judgment and eviction – necessity to place facts not before court – proof of occupation – registered title prima facie ownership – rei vindicatio – abuse of process and punitive costs
25 June 2025
First purchaser’s prior equitable rights prevail; transfer made in contempt of an extant interdict is void and cancellable.
Property law – double sale – first purchaser’s priority (qui prior est tempore potior est jure); provisional interdict (lis pendens) – extant court orders must be obeyed until set aside; bona fide purchaser with notice – no indefeasible title; laches/delay – not a substitute for judicial discharge of injunction; Deeds Registries Act s8 – court-ordered cancellation of registration
25 June 2025
A council must produce a valid council resolution authorising litigation; blanket or aged authorisations and chairperson’s letters are insufficient.
Civil procedure — Authority to litigate — Requirement for board/council resolution when authority challenged — Blanket/anticipatory resolutions invalid — Statutory bodies not exempt — ss 52 and 149 RDC Act do not confer automatic litigation authority — Chairperson’s letter not a substitute for council resolution
25 June 2025
Seizure lawful: owner’s indemnity constituted consent and reasonable suspicion justified warrantless seizure under the CPEA.
Criminal Procedure and Evidence Act – seizure of suspected stolen vehicle – reasonable suspicion under s49 – warrantless seizure and consent under s51 – indemnity/caveat subscriptor – s63 removal requires court order
25 June 2025
20 June 2025
19 June 2025
Applicant awarded custody; respondent ordered to pay maintenance, school fees, and given structured access.
Family law – custody of minor children – best interests of the child paramount – mother awarded custody – access to non-custodial parent – maintenance and school fees – Guardianship of Minors Act; Maintenance Act; s 81(2) Constitution
19 June 2025
A complainant’s reasonable police report after investigation does not establish malicious prosecution against the respondent.
Delict — Malicious prosecution — Instigation versus reporting to police — Reasonable and probable cause — Malice/animus iniuriandi — Complainant investigations and acquittal not determinative
19 June 2025
19 June 2025
Refusal of further remand discontinues proceedings and magistrates must determine and order restoration of seized exhibits under ss58/61 CP&EA.
Criminal procedure – Seizure and custody of exhibits – s58 and s61 CP&EA – refusal of further remand = discontinuation – magistrate’s power to determine entitlement/ownership – mandatory restoration absent proof of superior title.
18 June 2025
Beneficiary cannot compel trustees to produce subsidiaries' company documents; separate corporate personality and pleading requirements preclude mandamus.
Trust law – trustees’ duty to account limited to trust assets; Company law – separate legal personality; Mandamus – requirements of clear right, injury and absence of alternative remedy; Corporate veil – may not be pierced without pleaded exceptional circumstances and joinder of companies; Procedural – claims stand or fall on founding affidavit; inadmissibility of without-prejudice communications as proof.
18 June 2025
Acquittal where State failed to prove accuseds' presence, participation or common purpose in fatal stabbing.
Criminal law – Murder – No eyewitness to stabbing – Identification evidence and witness credibility – Doctrine of common purpose (s196A) – Acquittal for failure to prove presence, participation or mens rea.
18 June 2025
17 June 2025
Applicant failed to show good and sufficient cause and prospects of success to rescind a default judgment under the Commercial Court rules.
Civil procedure – Commercial Court r 21(2) and r 15 – rescission of default order – requirement to show good and sufficient cause and prospects of success – effect of IECMS notifications – imputation of attorney’s negligence to litigant
17 June 2025
Applicant failed to show good and sufficient cause to set aside a default judgment under rule 21(2).
Commercial Court — Rule 21(2) rescission of default judgment — good and sufficient cause (explanation, bona fides, prospects) — admissibility of affidavits (hearsay; rule 31) — oral contract proof — deed of pledge — finality and expedition in commercial litigation.
17 June 2025
17 June 2025
Whether co-applicants in motion proceedings may be separately represented and sever their case under court rules.
Civil procedure – representation of co-applicants – severance of case – interpretation of Commercial Court Rules r 53(1) and High Court Rules r 56(21)/Order 49 r 442 – motion versus trial proceedings – reading‑in to cure drafting errors.
16 June 2025
Bar for failure to file a replication applies only to replication filing; removal granted for genuine mistake, no costs.
Civil procedure – Rule 40(9) replication bar – bar limited to filing replication and does not suspend prosecution of action; r 39(4) limitations inapplicable; wilful default test; prospects of success not decisive in removal of replication bar; removal of bar and filing within 10 days; no order as to costs
13 June 2025
Owner entitled to summary eviction and removal where respondent failed to disclose a bona fide defence.
Property law – actio rei vindicatio – owner’s right to possession; Summary judgment – requirement to disclose bona fide defence; Misjoinder – inadequate to defeat substantive claim absent credible evidence; Costs – legal practitioner–client scale for vexatious or dilatory conduct
13 June 2025
13 June 2025
Interim anti-dissipation interdict granted to preserve applicant’s 50% share of jointly-owned rental income pending main action.
Interim relief – Anti-dissipation interdict – Joint property rentals – Prima facie right to income – Irreparable harm – Balance of convenience – Urgency – Affidavit authentication (r85 SI 202/2021).
13 June 2025
Plaintiff failed to show lawful adoption of a pre‑incorporation acknowledgment and authorised signatory, so absolution granted.
Civil procedure – absolution from the instance – prima facie case test; Company law – pre‑incorporation contracts and s 32 ratification; Contract law – validity and authority of signatory; Liquid document – ambiguities and misdescription
12 June 2025
Condonation refused for inordinate delay, unreasonable explanation, and no prospects of success; s48 lawfully applied.
Administrative law — condonation for late review — High Court Rules r62(4) — Administrative Justice Act s3(1)(c) and s6 — un‑commissioned affidavit invalid — Police Act s48 — lawful discharge by Commissioner‑General — no prospects of success on review
12 June 2025
A default judgment granted despite a late but filed notice of opposition was erroneously granted and was set aside; barred litigants retain limited rights to be heard.
Civil procedure – rescission of default judgment – rule 449 – effect of out‑of‑time notice of opposition on default judgment – barred litigant’s limited right to be heard – duty to give notice or seek strike‑out before seeking default judgment
11 June 2025
Application for leave to sue denied where claim is unpaid terminal benefits falling within Labour Act jurisdiction; Labour Court is the proper forum.
Insolvency Act s126 — leave to sue during corporate rescue; procedural form of application — chamber v court; Labour Act s13 — unpaid terminal benefits constitute unfair labour practice; forum competence — Labour Court as forum of first instance for s13 disputes; balancing creditors' interests and rescue culture when granting leave
10 June 2025
An interdict cannot substitute for eviction where the applicant lacks a clear right and is not in occupation of the land.
Civil procedure – interdict – requirements for final interdict (clear right, onus, irreparable harm) – possession and occupation – interdict not appropriate remedy for eviction – admissibility/weight of documents filed in answering affidavit – jurisdiction and forum.
10 June 2025
Application to demolish structure on court-declared owner’s stand dismissed; prior judgment operative and constitutional protection not engaged.
Civil procedure — Application for demolition of structure — Reliance on extant ownership judgment — Superannuation of judgments — Rule 69(3) and writs — Effect of rescission application on operation of judgment — s 74 Constitution (eviction/demolition) not engaged where structure not shown to be a home.
10 June 2025
Failure to plead prospects of success in the founding affidavit renders a condonation/reinstatement application fatally defective.
Civil procedure – condonation and reinstatement of appeal – requirements: extent of delay; explanation for delay; prospects of success must be pleaded in founding affidavit – heads of argument cannot cure pleadings deficiency
9 June 2025
Failure to pay prescribed security for respondent's costs renders a notice of appeal nullity; appeal struck off with costs.
Civil procedure – Appeals – Magistrates’ Court (Civil) Rules Order 31 – Requirement to pay security for respondent’s costs when noting appeal – Notice of appeal nullity if no payment – Undertaking not a substitute – Clerk’s discretion limited – Order 34 inapplicable to cure non-compliance
9 June 2025
Appellants’ identification and common purpose proved; sentencing was proper and appeal dismissed.
Criminal law – Robbery – Identification evidence and alleged dock identification – Similar fact evidence and modus operandi – Common purpose/co‑perpetration – Sentence discretion and concurrency – Appeal dismissed.
9 June 2025
Capital gains tax accrued on the 2010 sale; SI33(2019) did not convert an unassessed USD liability to RTGS.
Capital gains tax – timing of accrual and assessment – s 6, s 8; Conveyancers’ withholding/remittance duty – s 22C; Currency conversion SI 33 of 2019 – applies only to obligations valued and expressed in US$ immediately before 22 Feb 2019; Deeds Registry/title not determinative of accrual.
9 June 2025
Court distinguishes res judicata from a stay; appeal dismissed because no valid, served review application existed.
Civil procedure — res judicata vs stay of proceedings — distinction between substantive bar and discretionary stay; requirement of proper institution and service of review proceedings against administrative decision-maker.
9 June 2025
A minister deemed party to bargaining may set aside an arbitral award that unlawfully compels a public entity to exceed its approved budget.
Labour law – collective bargaining involving state-controlled statutory bodies – Minister deemed party under s 74(7) – arbitral award conflicting with public finance legislation – public policy under Article 34(2)(b)(ii) – awards exceeding approved public entity budgets unlawful and reviewable.
6 June 2025
A confirmed warned and cautioned confession, held voluntary, supports a murder conviction and 30-year sentence for the accused.
Criminal law — Confirmed warned and cautioned statement — Admissibility and voluntariness (s256(2)); Confession as basis for conviction where offence proven (s273); Joint liability/common purpose (s196A); Murder with actual intent (s47(1)(a)); Sentencing — aggravating factors, presumptive 20-year guideline.
5 June 2025
Applicants ordered to pay higher-scale costs for vexatious conduct in pressing interlocutory proceedings after main case dismissal.
Civil procedure — costs — award of attorney-and-client costs for vexatious, frivolous or mala fide conduct — setting down interlocutory matter after main matter dismissed — abuse of process; party-to-party costs where consented
4 June 2025
Applicant failed to prove a customary marriage; documentation of being held out as married was insufficient for surviving spouse status.
Administration of Estates Act – surviving spouse status – proof of customary law marriage – payment of lobola and cultural rites – evidentiary requirements in motion proceedings – declaratory relief under s 14 High Court Act
4 June 2025
A declaratory application cannot overturn an extant default judgment; affected parties must seek rescission or review under the Rules.
Civil procedure — Declaratory relief — Improper use of declaratur to challenge an extant default judgment — Rescission/review under High Court Rules (Rule 27, Rule 29) is the proper remedy — Court orders bind State and affected persons
4 June 2025
Whether the applicant’s review was time-barred and whether the respondent’s seizure decision was unlawful and grossly unreasonable.
Administrative law – review under Administrative Justice Act – prescription: s193(12) (seizure) vs s196(2) (other civil proceedings) – tourist rebate/regulations s104 – requirement for decision to relate law to facts – seizure/forfeiture – insufficiency of SARPCCO as proof of permanent exportation – grossly unreasonable administrative decision
3 June 2025
A fuel supply agreement and securities entered without required exchange control approval are illegal and unenforceable.
Exchange Control Regulations s11 — requirement for exchange control authorisation before incurring obligations to pay outside Zimbabwe; illegality of contract — void ab initio; special plea in bar — decidable on the papers; condition precedent — registration with Exchange Control Authorities.
3 June 2025