Supreme Court of Zimbabwe - 2015

46 judgments
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46 judgments
Citation
Judgment date
November 2015
Repeated renewal of fixed‑term contracts does not, under s 12(3), automatically convert them into permanent employment.
Labour law – Fixed‑term contracts v casual work – Interpretation of s 12(3) Labour Act – Casualisation of labour – Role of international labour instruments (ILO C158) in statutory interpretation – Domestic incorporation and binding effect of treaties.
20 November 2015
Electoral Court had jurisdiction to grant s70 access, but applicant’s failure to join necessary interested candidates and mootness doomed the application.
Electoral law — access to sealed ballots under s 70(4) — harmonised elections — s 167(2)(b) Constitutional Court jurisdiction limited to Presidential-election disputes — joinder of necessary parties — no lacuna preventing conditional orders under s 70(5).
17 November 2015
Substantial compliance with s38 notice and bona fide purchase uphold statutory sale and transfer of secured property.
Agricultural Finance Act s38 — notice before seizure; 'borrower' includes surety; substantial compliance with registered demand sufficient; statutory sale equated to judicial execution; protection of bona fide purchaser.
16 November 2015
Whether condonation should be granted for a 12‑month delay to appeal an arbitrator's award given lack of prospects of success.
Labour law — Condonation — Extension of time to appeal arbitration award — Test: extent of delay, explanation, prospects of success, prejudice — No misdirection by arbitrator on bonus, salary, vehicle, shares — Appellate interference with discretion limited.
16 November 2015
A signed guarantee in blank is binding absent vitiating factors; a hypothecation limit does not restrict a separate unlimited guarantee.
Contract and suretyship – signing in blank – caveat subscriptor – defences required to avoid signed document (misrepresentation, fraud, duress, undue influence, mistake) – distinction between hypothecation security limit and separate guarantee – joint and several liability.
16 November 2015
October 2015
Whether the appellant's reinstatement was before the arbitrator and the correctness of damages, salary and punitive damages.
Employment law – unfair dismissal – reinstatement v damages in lieu; interpretation of s 89(2)(c)(iii) Labour Act – punitive damages; requirement of evidentiary basis for quantum of damages; calculation of salary and contractual benefits.
20 October 2015
Whether a jurisdictional objection must be raised by special plea or may be decided on exception where no prejudice arises.
Civil procedure – Exception versus special plea – rr 99, 106 and 137 – Absence of jurisdiction – When jurisdictional objections may be decided on exception – Labour law jurisdictional issues.
20 October 2015
An applicant who raises new grounds on review after exhausting internal remedies will generally be precluded from doing so; appeal dismissed.
Labour law — review proceedings — points not raised before internal appeal — waiver — criteria for admitting new points on appeal (pleadings coverage, unfairness, facts common cause, absence of need for further evidence) — procedural strictness in labour disputes.
19 October 2015
Termination of a fixed-term contract with statutory notice is not automatically unfair; unsupported arbitral awards must be set aside.
Labour law – fixed-term contracts – statutory notice s 12(4)(d) – unfair dismissal under s 12B(3) – burden of proof for monetary claims – arbitral award set aside for lack of evidence.
16 October 2015
A court may not read into legislation a power to reinstate a deregistered estate agent; applicant's appeal dismissed.
Estate Agents Act – deregistration and disciplinary sanctions – absence of statutory provision for reinstatement – limits of judicial interpretation – court may not read-in powers amounting to legislation – Administrative Court jurisdiction.
2 October 2015
August 2015
Appellants' claim for rescission failed because they had taken control of the business; default judgment upheld and appeal dismissed.
Civil procedure – rescission of default judgment – willful default and bona fide defence – control/possession of business as evidence of operative agreement – appellate interference with discretionary refusal to rescind.
17 August 2015
Whether a labour court may convert an appeal to a review post‑hearing and order retrial despite evidence proving misconduct.
Labour law – procedure – Labour Court’s jurisdiction under Rules 12, 15, 16 and 26 – impermissible conversion of appeal to review post‑hearing – natural justice – disciplinary procedure – investigator presiding over hearing – alleged bias – reinstatement v damages – employee’s duty to mitigate – credibility of eyewitness evidence.
17 August 2015
Appellant's dismissal of respondent upheld where arbitrator misdirected and prior warning was relevant to penalty.
Labour law – unfair dismissal – arbitration review – arbitrator’s misdirection and appellate interference – employer’s managerial discretion to dismiss where misconduct goes to root of contract – relevance of prior severe written warning to penalty assessment – selective punishment/victimisation argument.
5 August 2015
Confirmed conviction and death sentence: confession corroborated, no extenuation, constitutional provision s48(2) not retrospective.
Criminal law – Murder – Confession corroborated by evidence – Conspiracy and accomplice liability – Extenuating circumstances – Death penalty – Non-retroactivity of Constitution s48(2) – Appellate review of sentencing.
2 August 2015
July 2015
Procedural irregularities and a chairman’s multiple roles created prejudice and warranted remittal for a fresh disciplinary hearing.
Labour law — Disciplinary proceedings — Procedural fairness — Reasonable apprehension of bias where chairman also acts as complainant and minute-taker — Requirement for worker representation — Remittal for hearing de novo where prejudice shown.
31 July 2015
Dismissal for altering a delivery voucher was unreasonably harsh; misconduct was excusable and did not warrant summary dismissal.
Disciplinary law — dismissal — employer's discretion on penalty — reasonableness and misdirection — misconduct inconsistent with employment contract — trivial/excusable misconduct — NEC and Labour Court intervention.
28 July 2015
Attorney-General may withdraw delegated prosecutorial authority but must comply with administrative justice (audi alteram partem).
Criminal procedure and administrative law – delegation of prosecutorial authority – certificate to prosecute – withdrawal of delegation – administrative justice (audi alteram partem) – reviewability of Attorney-General’s administrative acts.
27 July 2015
An arbitrator cannot impose terms of a collective bargaining agreement; negotiable allowances require party agreement.
Collective bargaining agreements – s 74(3) negotiable matters – Arbitrator's powers in compulsory arbitration – Referral to arbitration by agreement (s 93(1)) – Labour officer and arbitrator’s conciliatory role in interest disputes.
26 July 2015
A lateral transfer without reduced benefits does not constitute constructive dismissal absent prompt repudiation by the respondent.
Labour law — Constructive dismissal (s 12B(3) Labour Act) — Employer's right to transfer employees — Transferability clause and employee's knowledge — Requirement of prompt repudiation by employee — Absenteeism as misconduct.
26 July 2015
Appeal allowed: premature hearing of late exceptions and reliance on extraneous evidence reversed; matter remitted for trial.
Civil procedure – Exceptions and special pleas – late filing and non‑compliance with High Court Rules; hearing exceptions at trial after pleading over – impermissible; exception must be decided on the four corners of the pleading; relief on upheld exception ordinarily: set aside offending pleading and grant leave to amend; misuse of extraneous evidence on exception.
22 July 2015
Condonation for late appeal dismissed for unexplained delay, lawyer negligence, and lack of prospects of success.
Civil procedure – condonation for late noting of appeal – extension of time – factors: length of delay, explanation, bona fides, prospects of success, prejudice and finality; Registration of arbitral award – award satisfied by payment; award not sounding in money – non‑registrable.
22 July 2015
Appeal upheld only to set aside a newly raised withholding-information finding; gross negligence and dismissal otherwise affirmed.
Labour law – arbitration review – misdirection on facts as a point of law; substitution of findings by Labour Court; gross negligence in procurement and unauthorized payment; competence to introduce new findings on appeal.
21 July 2015
The respondent retained the common-law right to terminate employment on notice; s12B governs dismissal procedures only.
Labour law — Termination on notice vs dismissal — Interpretation of ss 12B and 12(4) Labour Act — Common-law right to terminate on notice preserved — Notice periods regulated by s12(4).
16 July 2015
The High Court may review inferior court proceedings under s29(4) even absent an appeal under s198(4).
High Court Act s29(4) — review powers of High Court where inferior court proceedings come to its notice; Criminal Procedure s198(4) — appeal by Attorney General; review of magistrate's discharge at close of State case; prima facie threshold versus proof beyond reasonable doubt; irregular proceedings and remittal for continuation of trial.
14 July 2015
Whether a collective agreement mandated salary adjustments equal to agreed inflation figures or merely a negotiation baseline.
Collective bargaining – Interpretation of clause providing that year-on-year inflation figures shall determine salary reviews – Arbitrator’s award ultra vires – Clause 9 permits individual institutions to grant higher non-binding increases – Arbitration and Labour Court review.
8 July 2015
Trial court’s factual findings upheld: appellant liable for outstanding account; appeal dismissed with costs.
Contract/Commercial law – credit account and identity of contracting party – account run in appellant’s name despite invoices issued in alternative trading names; Evidence – admission of debt – letter on appellant’s letterhead held to be admission; Civil procedure – r 188(1) High Court Rules – effect of failure to reply to notice to admit documents; Appellate review – deference to trial court’s factual findings unless irrational or clearly wrong.
8 July 2015
Non-compliance with an arbitral award pending appeal does not, by itself, bar the right to be heard or require interim relief.
Labour law — Appeal against arbitral award — s92E(2) and (3) Labour Act — noting an appeal does not suspend operation of award — interim determination discretionary — 'dirty hands' principle inapplicable where no obligation to comply — executability of award.
6 July 2015
Unauthorised disclosure of confidential salary information by a workers' representative justified dismissal; procedural defects unproven.
Labour law — Confidentiality and Code of Conduct — Unauthorised disclosure of employee salary information — Workers' committee status does not authorise breach of employer confidentiality rules — Procedural irregularity must be pleaded and proved to vitiate disciplinary proceedings — Unfair dismissal challenge dismissed.
1 July 2015
Prescription plea dismissed; 36-month damages reduced to six months and currency conversion remitted to the Labour Court.
Labour law – prescription – raising point for first time on appeal; Quantum of damages in lieu of reinstatement – need for evidence on age, health, qualifications and mitigation; Currency denomination – conversion of Zimbabwe dollar awards to foreign currency is within Labour Court’s equitable jurisdiction; Remittal for computation and conversion.
1 July 2015
June 2015
Supreme Court remitted the matter for trial because material constitutional and dismissal issues were not ventilated below.
:[
29 June 2015
The applicant's procedural complaints failed; uncontroverted witness evidence upheld dismissal for theft.
Employment law — Disciplinary proceedings — Procedural irregularities and fairness of hearing — Appellate review of disciplinary findings — Uncontroverted witness evidence and failure to cross-examine.
26 June 2015
Post-hearing, actual demonstrated bias and prejudice—not mere possibility—must be shown to nullify disciplinary proceedings.
Labour law — Disciplinary proceedings — Bias and recusal — Distinction between pre-hearing possibility of bias and post-hearing requirement to prove actual bias and prejudice — Fairness standard for workplace disciplinary hearings.
25 June 2015
Employees who wilfully boycott disciplinary hearings waive the right to later challenge those proceedings.
Disciplinary hearings — deliberate absence and waiver of right to challenge; workers' committee representation (s 24 Labour Act) — employer's duty to invite; Labour Court misdirection — inappropriate reliance on s 101(6).
8 June 2015
May 2015
Dismissal for gross negligence upheld where distribution manager failed to ensure crate collection, causing foreseeable significant loss.
Employment law – dismissal – gross negligence v ordinary negligence; supervisory duty and ensuring required operational resources; foreseeability of loss; standard of proof on disciplinary charge.
19 May 2015
April 2015
Rule 449 cannot be used to impose personal/de bonis propriis costs on an executor absent prior pleading or special circumstances.
Civil procedure — Rule 449 High Court Rules — correction/variation of judgment only where ambiguity, patent error or omission — costs — executor defending will — personal liability (de bonis propriis) requires pleading and exceptional circumstances — costs ordinarily follow the event; special costs against estate must be specifically claimed.
20 April 2015
March 2015
The respondent was entitled to payment for delivered equipment; set-off failed where the appellant hadn't cancelled contracts or proved defects.
Sale of goods — Delivery — Proof of delivery; Set-off (compensatio) — must be pleaded and proved, requires mutual, liquidated and due debts; Contract non-cancellation/mora — precludes set-off for non-delivery; Interest — runs from date of summons where no prior proper demand; Appellate review — will not disturb credible factual findings absent gross unreasonableness.
30 March 2015
Whether a single fatal stab during a scuffle constitutes actual intent or constructive intent and whether extenuation exists.
Criminal law – murder – distinction between actual and constructive intent – single fatal stab during scuffle – extenuating circumstances – sentence reduction from death to lengthy imprisonment – ownership and use of weapon.
29 March 2015
Appellant's dismissal for theft and unauthorised vehicle use upheld; reasons and mitigation opportunity found adequate.
Labour law — disciplinary dismissal — sufficiency of reasons in internal disciplinary findings — verdict 'guilty as charged' — proof of theft/fraud via documentary and witness evidence — opportunity to mitigate.
23 March 2015
Actual delivery triggers the three-month challenge period; apportionment by purchase contribution not contrary to public policy.
[Arbitration] Article 34(3) — receipt means actual delivery; Article 3 and 31 relevant to delivery. [Arbitration] Setting aside awards — public policy ground to be applied restrictively; requires palpable inequity/outrageous injustice. [Property/Lease] Apportionment of rental income may reflect parties' respective purchase contributions where those contributions reflect differing rentable value. [Civil procedure] Time runs from delivery, not mere advice that award is ready for collection.
18 March 2015
Arbitrator lacked jurisdiction to award relief for employees not before him; damages unsupported by evidence and dismissal upheld.
Labour law — arbitration jurisdiction and representation; procedural fairness in disciplinary hearings; applicable sectoral Collective Bargaining Agreement (S.I. 323/1993); assessment and quantum of damages for unfair dismissal; requirement for evidence and mitigation.
9 March 2015
High Court empowered to grant leave to sue where administrator unreasonably fails to act; appeal dismissed with costs.
Administrative Justice Act s3–s4 — relief for failure of administrative authority to act; High Court jurisdiction to review under other statutes (High Court Act s26); reviewable irregularity where administrator fails to act or give reasons; circumstances permitting court to grant relief rather than remit (delay, prejudice, foregone conclusion); Reconstruction Act s6(b) — leave to sue an entity under reconstruction; apportionment of costs.
5 March 2015
February 2015
Conviction for vague contractual misconduct set aside; aiding theft conviction upheld where employee authorised removal of items not on gate pass.
Employment law – disciplinary proceedings – charges including theft, aiding stealing and vague contractual misconduct – appellate review of factual findings – conviction for unspecified contractual misconduct set aside; aiding theft conviction upheld where employee authorised removal of items not described on gate pass.
25 February 2015
Illegal sale agreement unenforceable, but court may relax in pari delicto to prevent unjust enrichment and remit for valuation.
Property law – sale of unsubdivided portion – s39 Regional Town and Country Planning Act – Stamp Duties Act – illegality of contract – ex turpi causa non oritur actio – in pari delicto maxim – prevention of unjust enrichment – restitution/remittal for valuation.
22 February 2015
January 2015
Appellant’s agency, condition-precedent and impossibility defences fail; clear written contract and lack of objective impossibility justify summary judgment.
Contract law – interpretation and primacy of clear written terms; parol evidence/integration rule – extrinsic evidence not to contradict integrated agreement; agency – distinguishing independent distributor from agent and absence of privity; supervening impossibility (vis major/casus fortuitus) – objective impossibility required; summary judgment – requirement of bona fide defence; validity of affidavit – identification of commissioner of oaths.
26 January 2015
Supreme Court lacks jurisdiction under s 92F(3) where Labour Court dismissed leave application for procedural non-compliance rather than refusing it on the merits.
Labour Act s 92F – Appeals to Supreme Court – s 92F(3) requires prior refusal by Labour Court; procedural dismissal (Rule 36 non-compliance/condonation not sought) is not substantive refusal; Supreme Court lacks jurisdiction until Labour Court has refused leave on merits.
22 January 2015
A notice of appeal not stating whether it challenges whole or part is fatally defective and struck off the roll.
Civil procedure – Appeal – Supreme Court Rules r 29 – Notice of appeal must state whether appeal is against whole or part of judgment – Mandatory requirement – Failure to comply is fatal and cannot be amended – Matter struck off the roll.
12 January 2015