Supreme Court of Zimbabwe - 2014

81 judgments
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81 judgments
Citation
Judgment date
November 2014
Supreme Court set aside an unserved chamber order registering a retrenchment 'award' and quashed the consequent execution.
Civil procedure - chamber applications - Rules 226 and 242 - service of chamber applications - audi alteram partem - registration of retrenchment "award" - review powers s25 Supreme Court Act - appellate powers s22(1)(ix).
17 November 2014
Failure to furnish security for costs within r 46(5) justified dismissal of the appeal and attorney-and-client costs.
Civil procedure – Security for costs – Rule 46(5) peremptory one-month time limit – Failure to furnish security permits dismissal under r 36(1) – Judicial discretion under r 36(3) – Attorney-and-client costs awarded.
13 November 2014
October 2014
High Court retains jurisdiction over rei vindicatio claims; employee's expectation to buy a company car is not a legal right to retain it.
Labour law — scope of Labour Court's exclusive jurisdiction under s89(6); civil jurisdiction of High Court; rei vindicatio to recover company property; contractual/right-to-purchase under employer vehicle policy; suspension of dismissal and retention of employer property.
22 October 2014
Internal appointment to perform duties can satisfy s12B(3); three months' notice under s12B(4) does not apply to expiry by effluxion of time.
Labour law — Fixed‑term contracts — Unfair dismissal — s12B(3): legitimate expectation and replacement; internal/acting appointment suffices as engagement in employee's stead — s12B(4): three months' notice not applicable to expiry by effluxion of time — Remedies: reinstatement, damages, accrued leave pay.
17 October 2014
A workplace Code of Conduct does not displace the common law right to dismiss for misconduct that goes to the root of the employment contract.
Employment law – Code of Conduct v common law – Whether a workplace code can displace the common law right to dismiss for misconduct going to the root of the contract – Insobordination and summary dismissal – Burden on employee to show misconduct excusable or trivial.
16 October 2014
Bail pending appeal refused: appeal not reasonably arguable; religious indoctrination did not vitiate convictions; risk of absconding.
Criminal procedure – Bail pending appeal – test whether appeal is reasonably arguable; Credibility findings – appellate interference only if plainly wrong; Rape – consent vitiated by religious indoctrination and submission; Delay in reporting – plausibility and corroboration; Sentence – misdirection by failure to give reasons; Risk of absconding – positive grounds required for bail pending appeal.
15 October 2014
September 2014
Application for condonation of a nine-year delayed appeal refused due to inordinate delay, unsatisfactory explanation, and prejudice to respondents.
Civil procedure — condonation for late noting of appeal — factors: extent of delay; reasonableness and credibility of explanation; prospects of success not decisive where rule breach is flagrant; prejudice to respondents; need for finality — application dismissed.
29 September 2014
Non-urgent application should have been removed from the roll; trial court misdirected itself by deciding locus standi and merits.
Civil procedure — urgency — discretion to hear urgent applications — removal from urgent roll vs dismissal; locus standi — disputed facts and need for further evidence; misdirection by trial court in deciding merits on urgency; appellate restraint in first-and-last-instance decisions.
28 September 2014
Execution allowed despite a Constitutional Court appeal where the appeal lacked reasonable prospects and the prior eviction was void.
Civil procedure — Execution pending appeal — Discretion to grant leave to execute notwithstanding appeal to Constitutional Court — Factors: irreparable harm, prospects of success, balance of convenience — Spoliation/eviction order irregular and void — Restoration of possession — Costs on attorney-and-client scale.
22 September 2014
An employer may not impose a punitive transfer without a disciplinary finding and consultation; such a transfer is unlawful.
Labour law – Transfer of employee – Distinction between operational and punitive transfers – Punitive transfer unlawful without disciplinary hearing – audi alteram principle – Employer’s duty to consult and consider employee’s personal circumstances – Reinstatement and costs.
15 September 2014
Statutory immunity from execution under the Repeal Act applies to the single nominated successor company, not multiple successor entities.
Statute construction – Air Zimbabwe Corporation (Repeal) Act – meaning of 'successor company' – single designated successor company contemplated by s 3; statutory immunity from legal proceedings limited accordingly. Civil procedure – urgency – self-created urgency. Execution law – attachment of assets – proof of ownership; interpleader proceedings appropriate remedy. State liabilities – interaction of Repeal Act s9A and State Liabilities Act in protecting state-owned successor.
14 September 2014
Applicant failed to prove possession for mandament van spolie; overbroad final order was set aside.
Property — Mandament van spolie — Requirement to prove peaceful and undisturbed possession and unlawful dispossession — Evidence of possession — Interim/provisional relief versus final order — Competency of relief granted.
7 September 2014
Late supplementary affidavit withdrawing admissions refused for lack of explanation and prejudicial effect; appeal dismissed with costs.
Civil procedure — leave to file supplementary affidavit — requirements: satisfactory explanation, absence of mala fides, no irremediable prejudice — affidavit from legal practitioner required if omission blamed on counsel — withdrawal of admissions cannot be effected indirectly by supplementary affidavit — prejudice may justify refusal and punitive costs.
7 September 2014
Unauthorised transfer of employer property with admissions amounted to theft/misconduct; leave to appeal dismissed.
Labour law — Misconduct — Unauthorised disposal of employer's property; intention to permanently deprive inferred from conduct; recovery of property does not negate misconduct; leave to appeal refused.
2 September 2014
Leave to appeal dismissed; new employment contract valid, freely signed and not procured by duress.
Employment law - contract variation - mutual termination and replacement of contract following economic changes (dollarization) - validity of consent; Duress - requirements for setting aside contract; Procedural law - withdrawal of application after hearing; Leave to appeal - prospects of success.
2 September 2014
Rule 449 cannot be used to rescind a parallel judge’s order for substantive error; an appeal is the proper remedy.
Civil procedure — Rule 449 High Court Rules — correction, rescission or variation of judgments — rule applies to orders erroneously sought or granted (procedural errors, judgments in party's absence) — not a vehicle for correcting substantive errors made by a judge of parallel jurisdiction — functus officio — remedy for substantive error is appeal, not rescission.
1 September 2014
August 2014
Appellant bound by prior consent order fixing conversion date, so Labour Court’s USD award was upheld and appeal dismissed.
Labour law – back-pay conversion – date of conversion fixed by prior consent order – res judicata; currency revaluation regulations; public policy; appeal dismissed.
24 August 2014
Appellant failed to prove customary ‘evenness of turns’; appointment complied with VaZumba succession principles.
Traditional leadership — Customary succession — Whether ‘evenness of turns’ between houses forms part of succession — Role of guardian spirit (svikiro) in selecting chiefs — Admissibility and weight of oral genealogical tradition — Appellate restraint on disturbing factual findings.
13 August 2014
July 2014
Appeal against murder with actual intent dismissed; provocation and extenuation not established.
Criminal law – Murder with actual intent – Causation and fatal blow established by post-mortem; Provocation – defence rejected; Extenuating circumstances – onus on accused; allocutus and mero motu reopening of extenuation enquiry.
31 July 2014
An election petition must disclose grounds and exact relief on its face; failure to do so justifies dismissal.
Electoral law – Election petitions – Form and content – Rule 21(e) and (g) – Grounds and exact relief must appear on face of petition – Points in limine – s 171 trial requirement – statutory procedure – High Court Rules not applicable to displace electoral rules.
29 July 2014
Summary judgment reduced to US$2,760; damages claim for US$3,000 requires proof and may not be decided on summary judgment.
Civil procedure – summary judgment – exceptional remedy; admitted indebtedness convertible to US$2,760 – summary judgment appropriate; liquidated damages claim requires evidential proof and not suitable for summary determination; unsubstantiated factual defence (theft) insufficient.
29 July 2014
Appeal dismissed: identification and motive established arson‑murder of two children, no mitigation, death sentence affirmed.
Criminal law – Murder by arson – Identification by victim (voice and visual in moonlight) – Circumstantial evidence and motive – Alibi contradicted – No extenuation – Death sentence affirmed.
29 July 2014
Confirmed warned and cautioned statement admissible; evidence established violent rape and murder with actual intent; appeal dismissed.
Criminal law – rape and murder; admissibility of confirmed warned and cautioned statement – voluntariness; corroboration by medical and eyewitness evidence; intention and absence of extenuating circumstances; death sentence upheld.
29 July 2014
Self-defence rejected; second appellant convicted of murder with constructive intent; withdrawal ineffective; death sentences affirmed.
Criminal law – Murder – Actual and constructive intent – Self-defence – Common purpose and withdrawal/dissociation – Effectiveness of last‑minute withdrawal – Extenuating circumstances and death sentence.
29 July 2014
Failure to test psychiatric affidavit vitiated sentencing result; conviction upheld but death sentence reduced to 15 years for extenuating circumstances.
Criminal law – Murder – Expert psychiatric evidence given in affidavit – Duty to call expert viva voce where affidavit is inadequate or untested – Diminished responsibility/partial mental disorder as extenuating circumstances – Sentence substitution.
29 July 2014
Appellant's possession and concealment of the deceased's property supported conviction for murder and imposition of the death sentence.
Criminal law – Murder with actual intent – Circumstantial evidence – Possession and concealment of deceased's property shortly after killing – Murder to facilitate robbery – Death sentence in absence of weighty extenuating circumstances – Appellate interference in exercise of trial court discretion.
29 July 2014
Damages for wrongful dismissal of a fixed-term trainee are limited to proven loss for the unexpired contractual period.
Employment law – Fixed-term contracts – Measure of damages for wrongful dismissal limited to unexpired contractual period – Legitimate expectation of permanency – Sanctity of contracts – Mitigation and deduction of earnings.
28 July 2014
Appeal dismissed: appellants cannot repudiate pleaded contracts as shams and failed to pay required purchase price within three months.
Contract law – buyback/option agreements – interpretation of clause requiring payment within three months; Civil procedure – necessity to plead invalidity/sham – inability to pursue inconsistent relief; Security law – disguised surety argument rejected; Application of in duplum rule to sale/option price – not applicable; Cancellation of option for non-payment – lawful.
27 July 2014
Damages in lieu of reinstatement accrue from the date of wrongful dismissal; Labour Court to determine foreign-currency conversion and rate.
Labour law – consent order interpretation – damages in lieu of reinstatement – accrual from date of wrongful dismissal – mitigation of loss – computation and conversion of awards to foreign currency; equitable jurisdiction of Labour Court.
24 July 2014
Whether dismissal for sending obscene material via employer’s computer was justified and whether alleged hacking excused liability.
Labour law – dismissal for misconduct – use of employer’s IT facilities – incorporation of workplace policies into contract – allegation of hacking – adverse inference from silence in disciplinary proceedings.
23 July 2014
Acknowledgment of debt held not a suspensive condition; summary judgment upheld and appellant’s defence not bona fide.
Contract law — acknowledgment of debt — not a suspensive condition; Summary judgment — requirement of bona fide defence; Civil procedure — delay and dilatory tactics; Costs — attorney and client scale justified.
23 July 2014
Whether the Labour Court can grant interim relief against an arbitral award registered in the High Court pending appeal.
Labour Court jurisdiction — Registration of arbitral award in High Court — Effect on interim relief and appeals — Stay of execution pending Supreme Court determination — Conflicting High Court authorities.
23 July 2014
High Court erred in granting absolution: reconciliation statements created a stated account, Labour Act prescription inapplicable, exchange control burden on respondent, truck‑hire issues to be tried.
Civil procedure – absolution from the instance – stated account versus labour dispute; Labour Act jurisdiction and prescription; Exchange Control Regulations – burden of proof; locus standi to sue – ownership and pleadings re truck hire.
9 July 2014
June 2014
Appeal allowed: accused indemnified under s 3 Protection of Wild Life Act; conviction and death sentence set aside.
Criminal law — Murder — Self-defence and statutory indemnity — Protection of Wild Life (Indemnity) Act s 3 — Good faith requirement and acts in connection with suppression of unlawful hunting — Evaluation of witness credibility and resolving reasonable doubt in favour of accused — Extenuating circumstances and death sentence.
26 June 2014
Appellant restored to possession where respondent failed to prove spoliation and magistrate's eviction order was irregular.
Civil procedure — spoliation (mandament van spolie) — onus to prove peaceful possession and unlawful deprivation; vagueness of eviction orders; declaratory relief — jurisdiction of High Court; forum shopping allegations; appellate power to grant reinstatement and punitive costs.
16 June 2014
Employee’s persistent refusal to comply with a lawful transfer order constituted wilful disobedience justifying dismissal; lower court erred mero motu.
Employment law – Transfer of employee – Procedural fairness (audi alteram partem) – Willful disobedience of lawful order – Disciplinary dismissal – Appellate intervention for mero motu misdirection.
13 June 2014
Stay of execution refused: no prima facie right, defective notice of appeal, and service presumed regular.
Service of process — presumption of regularity of sheriff’s return; Stay of execution — requirement of prima facie right, irreparable harm and balance of convenience; Statutory tenancy — protection only while in actual possession; Notice of appeal — failure to state the court is fatal.
12 June 2014
A court may not decide a case on grounds not raised or argued; the overtime instruction was lawful and the appeal succeeded.
Labour law – arbitration and review – appellate review of Labour Court – court cannot decide on grounds not raised or argued by parties – lawfulness and clarity of employer's overtime instruction – appeal allowed.
9 June 2014
Leave to appeal granted on important labour-law issues about casualisation, legitimate expectations and s 12B(3)(b).
Labour law – casualisation – successive fixed-term contracts – legitimate expectation of permanent employment – interpretation of s 12B(3)(b) (engaging other persons) – reinstatement versus damages.
8 June 2014
Appellant entitled to occupation where valid offer letter followed compulsory acquisition; trial court misdirected in failing to decide the agreed issue.
Property law – compulsory acquisition of agricultural land – effect of bilateral agreements; Validity of offer letter as basis for occupation; Civil procedure – pre-trial agreement on issues; appellate intervention for misdirection and substitution of judgment.
1 June 2014
May 2014
Appellant failed to prove custom or contractual right to retain company vehicle; appeal dismissed with punitive costs.
Property law – actio rei vindicatio – owner proves ownership and defendant's possession; onus on defendant to prove right to retain; custom as source of law – requisites (reasonable, long established, uniform, certain); custom cannot substitute for an offer/contract; costs – legal practitioner and client scale for vexatious, unmeritorious appeal.
29 May 2014
Holder of an offer letter has enforceable right to occupy gazetted land; unlawful occupiers cannot rely on their own obstruction to defeat that right.
Gazetted land – compulsory acquisition – offer letters, permits and leases confer legal authority to occupy – holders entitled to assistance by courts and officials – unlawful occupation of gazetted land and offence under s 3(3) Gazetted Land (Consequential Provisions) Act – prescription cannot be relied on by those who frustrate claimant’s occupation.
27 May 2014
Appellate court upheld trial finding of fraudulent misrepresentation over share sale and dismissed the appeal with costs.
Partnership/contract – formation and tenure of partnership – fraudulent misrepresentation inducing share purchase – credibility findings and appellate restraint on factual findings – refusal to admit new point of law on appeal.
22 May 2014
A trade union must demonstrate constitutional authority or mandate to sue; failure to prove such authority defeats standing to seek judicial management.
Labour law – trade unions’ capacity and authority to sue – requirement to act in terms of union constitution (s 29 Labour Act) – proof of mandate to institute proceedings – judicial management applications – affidavit authority and annexures.
14 May 2014
Murder in the course of robbery with no extenuating circumstances; death sentence affirmed.
Criminal law – Murder – Murder committed in the course of robbery – Extenuating circumstances – Sentence of death – Appellate review of trial court’s finding on extenuating circumstances – Warned and cautioned statement – Post-mortem evidence.
7 May 2014
Death sentence upheld where a youthful appellant committed a planned axe murder during robbery, with no extenuating circumstances.
Criminal law – Murder with actual intent – Robbery as aggravating factor – Evaluation of credibility – Extenuating circumstances and youthfulness – Two‑pronged sentencing approach – Death sentence upheld.
7 May 2014
Appeal against murder conviction and death sentence dismissed; circumstantial evidence supported finding of deliberate killing.
Criminal law – Murder – Circumstantial evidence – Inference of intent – Credibility findings – Appellate review – Absence of extenuating circumstances – Death sentence upheld.
7 May 2014
Appeal against murder conviction and death sentence dismissed; killing was vindictive, not a crime of passion.
Criminal law – Murder with actual intent – Evidence of intention from nature and location of injuries and confession – Distinction between crime of passion and vindictive killing – Sentencing; absence of extenuating circumstances – Appellate restraint on interfering with trial court’s moral judgment (S v Woods principle).
7 May 2014
Whether poisoning and subsequent fatal assault during a robbery established constructive and actual intent warranting the death penalty.
Criminal law – Murder – Poisoning and fatal assault during robbery – Constructive intent for poisoning death – Actual intent and joint liability for fatal assault where identity of striker unclear – Death penalty where no extenuating circumstances.
7 May 2014
Whether self-defence and youthfulness excuse a politically motivated pursuit-and-blow killing; conviction and death sentence upheld.
Criminal law – Murder with actual intent – Self-defence rejected where assailant pursued and struck victim from behind; evidence and admissions corroborate State case – Sentencing – Youth not extenuating where conduct inconsistent with immaturity – Politically motivated killing aggravates moral blameworthiness – Death sentence upheld.
7 May 2014