Supreme Court of Zimbabwe - 2004

48 judgments
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48 judgments
Citation
Judgment date
December 2004
Labour tribunal lacked jurisdiction to grant mandamus; delay in pursuing an internal appeal does not justify reinstatement.
Labour law – jurisdiction of Labour Relations Tribunal – mandamus – remedy for delay in prosecuting internal appeal – reinstatement versus mandamus – s89, s96, s97(4)(a) of the Labour Act.
15 December 2004
Award of backpay set aside for lack of evidence on mitigation; matter remitted for fresh assessment.
Labour law — Unlawful dismissal — Assessment of damages — Duty to consider mitigation — Need for evidence of attempts to obtain alternative employment — Oral submissions by counsel not evidence — Remittal for fresh quantification.
15 December 2004
November 2004
Whether a municipal defendant, though a contract may be void for tender non‑compliance, was unjustly enriched by extraction of applicant’s gravel and liable in restitution.
Contract formation – implied/tacit agreement; Municipal procurement/tenders – effect of non-compliance with s 211 Urban Councils Act on enforceability; Restitution – unjust enrichment elements (enrichment, impoverishment, lack of justification, measure of enrichment); Remedy – restitution despite invalid contract
22 November 2004
Appeal struck off roll: contract duration was a factual issue, not a question of law, so no Supreme Court jurisdiction.
Labour law — retrenchment regulations — fixed-term versus open-ended contracts — question of law v question of fact — appellate jurisdiction under s 92(2) Labour Relations Act — appeal struck off roll
15 November 2004
A consent order cannot be appealed; under s92D appeals lie only on questions of law and consent orders present no such issues.
Civil procedure – Consent orders – Appealability of judgments by consent – Consent orders not subject to appeal; may only be set aside for fraud or common mistake; Labour Relations Act s92D limits appeals to questions of law
4 November 2004
October 2004
A valid execution sale cannot be set aside where the applicant accepted the balance and paid debt only after sale.
Execution — sale in execution by Deputy Sheriff — validity of sale — setting aside sale where judgment debt paid after sale — acceptance of sale proceeds as affirmation of sale — alleged misleading advice by legal practitioners not a ground to set aside sale; separate contractual/tort claim may lie against practitioners.
17 October 2004
Extension granted where acquiring authority vested ownership and respondent’s continued occupation was unlawful.
Land acquisition – effect of service of order of acquisition – ownership vests in acquiring authority; s 9(1)(b) obligations to vacate; allocation of acquired land pending confirmation; extension of time and condonation for late appeal – solicitor’s fault; eviction where occupier remains unlawfully after acquisition
11 October 2004
Appeal dismissed: tribunal correctly found no prescription, jurisdiction was proper, and notice defect was not fatal.
Labour law – prescription of disputes (s.94 Labour Relations Act) – jurisdiction of Labour Relations Officer – contents and cure of defective notices (S.I. 30/1993, s.14) – sectoral Code of Conduct and timing – suspension, dismissal procedure and effect of S.I. 371/85.
10 October 2004
Applicant's appeal reinstated: Supreme Court rules include vacation days in time computation; reasonable mistake and prospects justified reinstatement.
Civil procedure — Reinstatement of appeal deemed abandoned — Computation of time for filing heads of argument — Vacation days included under Rule 3 of Supreme Court Rules — Rule 58 not permitting adoption of High Court Rule 238(2a)(i) where Supreme Court Rules differ — Reasonable explanation and non‑inordinate delay — Prospects of success on appeal
5 October 2004
September 2004
The applicant’s factual challenge did not raise a point of law; the Supreme Court lacked jurisdiction and struck the appeal off the roll with costs.
Labour law — Appeal from Labour Relations Tribunal — Section 92(c) Labour Relations Act — Appeal lies only on points of law — Factual findings not reviewable by Supreme Court — Appeal struck off the roll with costs
29 September 2004
The appellant's dismissal was upheld for misconduct committed while a final written warning remained operative.
Employment law — Misconduct and progressive sanctions — Final written warning in force — Subsequent similar misconduct justifies dismissal; quantum of loss and internal procedural lapses immaterial once offence admitted
27 September 2004
A negotiated resignation and signed release preclude a subsequent unfair dismissal claim where no duress is alleged.
Labour law – termination by resignation – effect of negotiated settlement and signed release – abandonment of internal remedies – Tribunal’s misdirection for disregarding documentary evidence.
26 September 2004
Failure to follow a registered Code of Conduct and natural justice renders dismissal unlawful; employer liable for suspended pay.
Labour law — Registered Code of Conduct — Procedural compliance required before dismissal — Natural justice — Failure to follow Code renders dismissal unlawful — Remedy: payment for period of suspension where reinstatement not sought
22 September 2004
Appeal dismissed: provisional judicial management upheld where indebtedness, mismanagement and just-and-equitable factors were established.
Companies law – provisional judicial management – statutory requirements under ss 205(c), 299(1)(a) and 300(a) – inability to pay, mismanagement and just and equitable test – appellate restraint in reviewing exercise of judicial discretion – admissibility of post-filing allegations in answering affidavit
22 September 2004
A notice of appeal omitting the decision date is fatally defective; cannot be amended and requires a fresh notice plus extension and condonation.
Civil procedure – appeals – notice of appeal – requirement to state date of decision – failure to state date renders notice fatally defective – nullity cannot be amended – remedy is fresh notice with application for extension and condonation; costs de bonis propriis against counsel for negligent conduct
20 September 2004
An appeal from a court martial must first be heard by the Court Martial Appeal Court before the Supreme Court.
Defence Act — ss 78, 79, 80, 88A — Court Martial appeals — Composition of Court Martial Appeal Court (High Court judges appointed by Judge President) — Appellate route: Court Martial → Court Martial Appeal Court → Supreme Court — Jurisdictional competency.
13 September 2004
Whether the court should relax in pari delicto to order restitution for money lost in illegal foreign-exchange transactions.
Exchange control/illegal foreign-exchange dealings – in pari delicto potior est conditio possidentis – restitution claims where money lost to third-party fraudsters – unjust enrichment – appellate deference to trial findings on credibility
9 September 2004
Persistent defiance of court orders and absence of good grounds justified dismissal of rescission application and appeal.
Civil procedure – eviction – default judgment and warrant of eviction – application for rescission – persistent defiance of court orders and contempt – failure to establish good cause – appeal dismissed with costs
9 September 2004
Use of fabricated exchange rates constituted dishonesty warranting dismissal; Tribunal’s finding upheld.
Employment law — Dismissal for dishonesty — Use of incorrect exchange rates to appropriate employer funds — Proof on balance of probabilities — Group III offences under National Employment Code — Prior final written warning — Tribunal’s factual inferences upheld.
9 September 2004
An employee who signs and accepts benefits under a written mutual termination agreement is bound absent duress or lack of knowledge.
Labour law – termination by mutual agreement – written agreement binding absent allegation of duress or lack of knowledge – effect of employee accepting terminal benefits – irrationality of Tribunal finding
8 September 2004
Whether a probationary employee can be reinstated after dismissal for dishonesty despite employer's procedural defaults.
Employment law — Probationary dismissal — Dishonesty by security guard — Effect of employer’s non-attendance at hearings — Review of Labour Relations Tribunal order
8 September 2004
Referral for authority to dismiss was prescribed; no evidence showed multi‑count charges were filed within 180 days.
Labour law — dismissal procedures — prescription of referral under s 94(1)(b) — requirement that charges be the basis of referral — remittal for rehearing where new allegations introduced.
6 September 2004
June 2004
Refusal of bail affirmed where serious exchange control charges, strong prima facie case and substantial foreign assets created real risk of abscondment.
Criminal procedure – Bail pending trial – Risk of abscondment – Assessment of strength of State’s prima facie case – Consideration of accused’s foreign assets and foreign passport/residency – Particularity and credibility of defence explanation – House arrest and medical grounds – Appeal court’s restraint in reviewing discretionary bail refusals.
16 June 2004
Condonation refused; executor validly authorised to sell estate property; appeal dismissed for lack of merit.
Administration of estates – executor’s authority – validity of appointment by Assistant Master; condonation – upliftment of automatic bar – delay and negligence; sale of estate property – setting aside – prospects of success
9 June 2004
Possession of foreign funds and bare interference allegations do not automatically justify refusing the applicant bail.
Exchange Control Act – bail – risk of abscondment – allegations of interference with investigations – weight of evidence required to deny bail – relevance of repatriation and ties to jurisdiction
2 June 2004
May 2004
Rescission refused: wilful default, implausible explanation, and no prospects of success on liability.
Civil procedure — Rescission of default judgment — requirements: reasonable explanation for default, bona fides, prospects of success — service under Rule 39 — wilful default — effect of criminal convictions on prospects of success.
18 May 2004
Appeals from the Labour Court must raise questions of law; pure factual challenges without showing misdirection are not entertainable.
Labour law – Appeals from Labour Court – Appeal limited to questions of law (s92(2) Labour Relations Act) – Appellate review of factual findings only where findings are perverse or amount to misdirection in law
17 May 2004
Tribunal misdirected; employee’s wilful disobedience and misrepresentation justified dismissal.
Labour law – dismissal for wilful disobedience and misrepresentation; contractor approval instructions; review for factual misdirection amounting to error of law
12 May 2004
An innocent second purchaser’s transfer was set aside in favour of the respondents due to Deeds Office failure to register a caveat.
Property law – double sale of immovable property – priority of first contract – caveat and notice – effect of Deeds Office omission – innocent purchaser doctrine – absence of special circumstances.
12 May 2004
Whether an unlawfully dismissed, elderly unskilled employee who sought casual work reasonably mitigated his damages.
Labour law — wrongful dismissal — mitigation of damages — employee's duty to seek alternative employment — reasonableness assessed by age, skills and economic conditions — reduction of damages for failure to mitigate
10 May 2004
An applicant cannot obtain costs against a maintenance complainant absent any pleaded or evidential basis for such an order.
Maintenance law — committal for non-payment — urgent application for release — costs — no basis on pleadings to order a private complainant to pay costs — right to report maintenance default
10 May 2004
The appellants lacked standing; the offer was not a lease and subsequent acquisition notice required their eviction.
Land acquisition – ownership vests in acquiring authority on acquisition – locus standi – speculative reversionary interest insufficient; Offer letter – not a lease (no rent agreed) – Agricultural Land Settlement Act s9 inapplicable; Land Acquisition Amendment Act No.10/2002 s4(b) – subsequent order substitutes invalid order and triggers seven-day vacatur obligation
9 May 2004
Appeal reinstated due to former counsel’s last‑day renunciation despite prima facie poor prospects on the merits.
Civil procedure — Reinstatement of appeal — Rule 36/Rule 43(2)/Rule 44 — Good cause for default — Counsel’s last‑day renunciation/abandonment — Summary judgment — Right to be heard.
4 May 2004
Amendment cured alleged vagueness; creditor’s claim on an acknowledgement of debt sustained; appeal dismissed with costs.
Civil procedure – exception to declaration – whether pleadings are vague and embarrassing – amendment curing ambiguity – liquid document (acknowledgement of debt) – provisional sentence available
2 May 2004
March 2004
The appellant's late appeal was struck off for failing to seek condonation in Chambers and properly serve the respondent.
Civil procedure — Appeal noting time limits — Supreme Court (Miscellaneous Appeals and References) Rules 1975, rr.4–6 — Rule 5: 15-day notice — Rule 6: condonation by judge in Chambers only — requirement of service and opportunity to oppose — failure to comply; appeal struck off roll with costs.
10 March 2004
An employer may lawfully terminate on notice where removal of director status does not amount to misconduct or retrenchment.
Labour law – termination on notice – application of registered Code of Conduct – section 1A SI 377/90 – prior ministerial approval not required where no misconduct alleged – withdrawal of director status not necessarily demotion or retrenchment
1 March 2004
A notice of appeal failing to state the relief sought is a nullity; appeal struck off the roll for non‑compliance with Rule 29(1)(e).
Civil procedure – summary judgment – factual dispute as to reasonableness of charges and existence of oral agreement – claim not sufficiently liquid; Appeals – defective notice of appeal – non‑compliance with Rule 29(1)(e) (no prayer/relief stated) renders notice a nullity – condonation/amended notice required – appeal struck off roll with costs
1 March 2004
A purchaser may seek transfer or payment of equivalent value without pleading cancellation when the seller cannot deliver.
Sale of immovable property — purchaser's remedies — specific performance (transfer) or alternative payment of equivalent value — no need to plead cancellation before claiming value — ascertainability of value — amendment of pleadings.
1 March 2004
Condonation granted where delay was not inordinate and appeal raised arguable jurisdiction, prescription and res judicata issues.
Civil procedure – condonation for late noting of appeal – delay not inordinate where record assembly caused delay; Labour law – jurisdiction and prescription – earlier related proceedings may raise res judicata and prescription issues; point of law may be raised on appeal without cross-appeal.
1 March 2004
February 2004
Post‑judgment sale of land to manufacture fresh evidence cannot justify admitting it or defeating a validated acquisition.
Land acquisition; leave to adduce fresh evidence on appeal; post‑judgment fabrication of evidence; remittal inappropriate where decision rests on independent findings; resettlement necessity evidence
29 February 2004
Tribunal’s reinstatement was Wednesbury-unreasonable; admitted assault and failure to follow grievance procedures justified dismissal.
Labour law – dismissal for assault – standard of review: Wednesbury unreasonableness/irrationality – procedural irregularities vs merits – provocation/grievance procedures.
22 February 2004
A suspended employee who accepts other employment repudiates the original contract; damages limited to arrears up to that date.
Employment law – Suspension versus dismissal – Duty of suspended employee to remain available – Acceptance of alternative employment while suspended constitutes repudiation – Back-pay is part of damages – Proper period for assessment of arrears.
13 February 2004
Failure to return under bail conditions, unsupported by timely medical or procedural steps, renders an appellant a fugitive from justice and bars appeal.
Criminal procedure – Fugitive from justice – Locus standi in judicio – Whether illness or fear justifies absence from jurisdiction – Failure to seek extension of bail conditions; estreatment of bail and warrant of arrest.
11 February 2004
Whether the Tribunal’s dismissal decision was so grossly unreasonable as to justify appellate intervention.
Labour law – disciplinary hearings – competency of presiding officer; procedural fairness – notice and witnesses; appellate review – misdirection on facts/gross unreasonableness test.
11 February 2004
Refusal of bail upheld where judge considered prospects of appeal and risk of absconding under s 25(2)(c) CP&E Act.
Bail pending appeal – prospects of success – s 25(2)(c) Criminal Procedure and Evidence Act – duty to arrest for offences committed outside Zimbabwe – risk of absconding.
1 February 2004
January 2004
Possession of suspected stolen hospital property inferred from items wrapped in appellant’s clothing in her house; conviction upheld.
Criminal law – possession of property reasonably suspected to be stolen – inference of possession from goods found in accused’s home and wrapped in accused’s clothing – adequacy of accused’s explanation – s 14(1)(b) Miscellaneous Offences Act.
25 January 2004
Prompt lodging of transfer documents and possession can constitute special circumstances to set aside a sale in execution.
Property law – cession of lessee-to-buy rights – attachment and sale in execution of property registered in debtor’s name – judgment creditor’s prima facie right to attach – special circumstances required to set aside execution – prompt lodging of transfer documents and taking possession as special circumstances.
14 January 2004
An appeal from the Labour Relations Tribunal to the Supreme Court lies only on questions of law; none was raised, so appeal dismissed.
Labour law – Appeals from Labour Relations Tribunal – s 92(2) – appeal to Supreme Court only on question of law; distinction between law and fact; misdirection on facts standard; time limits for labour relations office intervention (s 94); internal appeals under employer's Code of Conduct
11 January 2004