Supreme Court of Zimbabwe - 2016

45 judgments
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45 judgments
Citation
Judgment date
December 2016
Whether non-parties may be added as respondents on appeal when they were not cited in earlier proceedings.
Civil procedure — Joinder vs substitution — Parties to original proceedings — Locus standi of non‑parties on appeal — Representative capacity of trade unions — Vague and embarrassing pleadings.
16 December 2016
November 2016
Conviction based on uncorroborated accomplice testimony was unsafe; sentence quashed for lack of reasons.
Criminal law — fraud — accomplice evidence — s 267 Criminal Procedure and Evidence Act — cautionary rule — necessity for corroboration implicating accused or other features removing danger of false incrimination — failure to warn; criminal procedure — sentencing — duty to give reasons — gross irregularity; conviction unsafe and sentence quashed.
28 November 2016
A revenue authority may appoint agents and garnishee accounts; trial court erred in mero motu administrative review and granting interdict.
Tax law – VAT Act ss 36 & 48 – power to appoint agents and garnishee bank accounts; ‘pay now, argue later’ principle; administrative review – limits on courts raising issues mero motu; interdicts not available to protect duties to pay tax; construction of s 14 Fiscal Appeal Court Act vs s 36 VAT Act.
24 November 2016
Failure to give reasons and not deciding a decisive preliminary point vitiated Labour Court orders substituting the employer; orders set aside.
Civil procedure — duty to give reasons — absence of reasons vitiates contested proceedings; Labour law — amendment of notice of appeal and proper citation; corporate veil — court's lack of jurisdiction to uplift; Supreme Court s25 review powers to set aside irregular proceedings.
17 November 2016
Longstanding failure to secure employer's bullion and remediate missing spare key constituted habitual neglect justifying dismissal.
Employment law – misconduct – custodial duties over employer’s property – breach of fundamental term – habitual and substantial neglect of duties – formulation of disciplinary charge – dismissal substantively fair.
7 November 2016
Arbitral damage awards must be evidence-based; employee failed to prove losses beyond the four-month unemployment period.
Labour law – wrongful dismissal – quantification of damages – onus on employee to prove loss – mitigation – damages limited to period until alternative employment found – arbitral awards must be supported by evidence; award without evidentiary basis unsustainable.
3 November 2016
A materially defective counter-application is a nullity; specific performance cannot be granted on a validly cancelled contract.
Civil procedure — Counter-application formalities (r 229A, r 230) — failure to use Form 29 renders counter-application invalid; Specific performance — cancelled contract — must set aside cancellation and show prestatement; Disputes of fact not resolvable on papers.
1 November 2016
Whether dismissal for failure to submit claims was justified and reinstatement order valid without damages alternative.
Labour law — dismissal for misconduct — negligence vs gross negligence — employer's discretion to treat misconduct as repudiatory — limited appellate interference — reinstatement orders must include damages alternative (s 89(2)(c)(iii) Labour Act).
1 November 2016
October 2016
The award was invalidated because the respondent failed to meet mandatory financial funding and bank guarantee tender requirements.
Procurement law — mandatory tender requirements — compliance with financial funding proposals and bank guarantees — administrative review — invalid tender award and setting aside of contracts and statutory certificate — remittal for fresh tender — legal ethics and abuse of court process; costs.
28 October 2016
Court remitted matter after trial court failed to decide the referred special case and exceeded its mandate.
Banking Act s54 – effect on shareholders of a bank under curatorship; special case procedure – pre-trial conference minute; court exceeding scope of referral; fundamental procedural irregularity; remittal.
13 October 2016
September 2016
Application to reinstate a lapsed appeal dismissed for non-compliance with mandatory rule requiring payment/undertaking for the record.
Civil procedure — reinstatement of lapsed appeal; Supreme Court Rules r34 (deposit/undertaking for record) — mandatory compliance; r26 inapplicable to civil appeals (Part IV criminal appeals); r4 (departure from rules) not to be used to circumvent mandatory provisions; condonation — onus on applicant; finality of litigation; costs — attorney–client scale.
29 September 2016
August 2016
An arbitrator and Labour Court may not replace an employer’s discretionary decision to dismiss for wilful disobedience absent misdirection or unreasonableness.
Labour law – wilful disobedience – transfers – dismissal discretionary under National Employment Code s4 and s7(3) – appellate interference only for misdirection or gross unreasonableness.
18 August 2016
An employer’s dismissal was invalid where the chairman improperly overturned a disciplinary majority and cast an unentitled deciding vote.
Labour law – limits on appellate review of factual findings – employer’s duty under s 6(1)(d) Labour Act – disciplinary procedure – majority decision binding; chairman’s casting vote only on equal votes (s 4(5) of Code) – unexplained duplicate minutes invalidating dismissal.
3 August 2016
July 2016
Refusal to correct a material mis‑citation renders proceedings improperly before the court and justifies striking off and punitive costs.
Civil procedure — mis‑citation/wrong party — locus standi — abuse of process — applicant cannot benefit from own wrong — wrong citation may render proceedings void — exemplary costs.
22 July 2016
A default judgment granted in error due to registry mistake must be rescinded under r449 without proving "good cause".
Civil procedure — Rescission of default judgment — High Court Rules r 63 versus r 449(1)(a) — Judgment erroneously granted — Court may invoke r 449 mero motu — No requirement to show "good cause" where judgment was granted in error — Inherent jurisdiction to correct patent errors.
21 July 2016
The applicant’s persistent noncompliance with an extant eviction order barred him from seeking condonation and appeal until he purged his contempt.
Civil procedure – condonation and extension of time – dirty hands doctrine – obligation to comply with extant court orders pending appeal or stay – purging contempt before seeking relief.
20 July 2016
Appeal dismissed: grounds challenged factual findings, not points of law, and the notice contained an incompetent remedial prayer.
Labour law – appeals against arbitral awards – section 98(10) Labour Act – appeals only on points of law – factual findings not reviewable absent pleaded gross misdirection or irrationality – defective notice of appeal – incompetent remedial prayer (remittal to court a quo).
5 July 2016
June 2016
A company placed in liquidation after commencing suit retains locus standi and need not seek leave to continue as plaintiff.
Company law — effect of liquidation on existing litigation — locus standi of a plaintiff-company placed under liquidation — interpretation of s 213 and s 221(2) of the Companies Act — procedural requirements for raising special pleas after litis contestatio — improper striking off of proceedings.
30 June 2016
Appellant must obey valid labour regulations and cannot seek judicial relief while refusing compliance (dirty hands doctrine).
Administrative law – Dirty hands doctrine – Obligation to obey valid statutory instruments pending judicial review – Collective bargaining agreements – Right of access to courts and property protection exercised consistently with obedience to law.
23 June 2016
Condonation for late noting of appeal refused due to no reasonable prospects of success despite some sympathy for applicant.
Civil procedure – condonation and extension of time to note appeal – application assessed under extent of delay, reasonableness of explanation, and prospects of success (Kombayi test) – credibility findings and evidence that property was sold inter vivos – no reasonable prospects of success – ordinary costs.
23 June 2016
An auctioneer earns commission upon conclusion of a sale; a retention clause is enforceable absent demonstrated disproportionality.
Auction law – Auctioneer’s commission – entitlement arises on conclusion of sale; Contractual Penalties Act s4 – reduction only if penalty disproportionate and factual basis proved; pleadings – closing submissions do not substitute for pleaded or proved facts; points of law may be raised on appeal if no unfairness.
21 June 2016
Application for leave to appeal dismissed for procedural default, failure to seek rescission/condonation, and inordinate delay.
Labour law – Leave to appeal – s 92F – appeal to Supreme Court decided afresh on merits; Procedural compliance – failure to file heads of argument; Rescission – s 92C required for orders made in absence; Rules r 26 and r 33 – condonation/extension; Inordinate delay and failure to exhaust remedies – grounds for dismissal.
15 June 2016
May 2016
Sale of whole property upheld; court erred in dismissing rescission for want of prosecution without considering merits and prejudice.
Property law – Regional Town and Country Planning Act s 39(1)(b)(i) – subdivision permits – agreements for change of ownership of portion of property; Civil procedure – High Court Rules r 236(3) – dismissal for want of prosecution – judicial discretion requires consideration of delay and explanation, prospects of success, balance of convenience and prejudice; Rescission of default judgment – procedural fairness and proper exercise of discretion; Irregularities – summary orders and judicial assignment.
31 May 2016
An employer’s disciplinary discretion (including dismissal) stands unless shown to be improperly exercised; prior warnings remain relevant to penalty.
Labour law – disciplinary penalty – employer’s discretion to dismiss – appellate interference only for misdirection or irrationality – relevance of prior warnings irrespective of chronology or exact similarity.
30 May 2016
Court upheld dismissal for gross negligence and proven sexual misconduct; charges were not prescribed.
Employment law – disciplinary procedure – prescription – when employer becomes aware of facts – gross negligence for failure to graft crop – sexual misconduct with junior staff – corroboration and credibility – dismissal as permissible sanction.
24 May 2016
Condonation granted; arguable appeal where respondent’s conduct, waiver and timely review of Master’s confirmation raise material disputed issues.
Succession and administration of estates – condonation of late appeal – reasonable explanation for delay – waiver by conduct and correspondence – review of Master’s confirmation of distribution under s 52(9) Administration of Estates Act – disputed factual issues requiring Master’s report or oral evidence.
23 May 2016
Misconduct destroying employer’s trust (removing confidential records, intimidation) warranted dismissal; appellate interference with arbitral penalty was proper.
Employment law – Misconduct going to the root of the contract – Removal of confidential personnel records and intimidation – Trust eroded — Appropriate penalty of summary dismissal – Role of mitigating factors under s 12B(4) of the Labour Act – Scope of appellate interference with arbitral discretion.
23 May 2016
Completion of a pension withdrawal form stating “leaving Conquip” constituted a communicated resignation, dismissal with costs awarded.
Employment law – Resignation as a unilateral act – Communication and form of resignation – Pension withdrawal form as notice – Employer acceptance by company official – Costs on legal practitioner and client scale for dishonest or frivolous litigation.
18 May 2016
April 2016
Applicant's leave to appeal refused for relying on non-appealable factual findings and defective notice of appeal.
Labour law – leave to appeal – appeal against factual findings of arbitrator – appealability – procedural compliance with notice of appeal – standard of irrationality for interfering with findings of fact.
26 April 2016
A respondent is not delictually liable for its lawyer’s wrongful eviction absent the respondent’s own wrongful participation or foreseeability.
Delict – liability for legal practitioner's delicts – mandatum/mandatary – client not vicariously liable absent participation or foreseeability; Aquilian action – requirements of wrongfulness and culpa and need for particulars; actio injuriarum – necessity to plead intentional infringement of personality rights; unlawful eviction and attachment.
6 April 2016
March 2016
Labour Court lacked jurisdiction to grant interdict or declaratory relief; retrenchment agreement and Board approval upheld.
Labour law – jurisdiction of Labour Court – interdicts and declaratory orders – statutory limits of Labour Court powers under s 89 – retrenchment procedures and Retrenchment Board approval – company law – separate legal personality and piercing the corporate veil.
29 March 2016
Failure to value attached goods and continuing sale after debt satisfied renders attachment and sales nullities.
Civil procedure — Attachment and sale in execution — High Court Rules r 335 (inventory and valuation mandatory), r 340 (sale to stop when sufficient funds raised), r 341 (excess funds), High Court Act s 20 (duties of sheriff), nullity of unlawful attachment and sale.
29 March 2016
A former spouse may recover arrear maintenance and medical expenses under s 11 despite informal variation and prescription defences.
Maintenance law – Arrear maintenance and reimbursement of medical expenses – Matrimonial Causes Act s 11 – Recovery by former spouse – Prescription and acknowledgement of debt – Dollarization and alleged impossibility – Informal variation of consent maintenance order enforceable – Best interests of the child – Costs (punitive scale).
22 March 2016
Deed of suretyship remained binding absent written cancellation; privileged lawyer-client letter was inadmissible without proof of waiver.
Contract — Suretyship — Requirement of written cancellation under deed clause — No novation where original suretyship not cancelled; Evidence — Legal practitioner-client privilege — Onus to prove waiver of privilege; Admission of privileged communication without proof of waiver is erroneous.
15 March 2016
Appeal dismissed: defective foreign power of attorney, late opposing papers, and judicial management sought as abuse to avoid contractual liability.
Companies law — Judicial management — Provisional and final judicial management under ss 300 & 305 — Abuse of process where application seeks to avoid suretyship/mortgage obligations; Authentication and translation of foreign Powers of Attorney — High Court (Authentication of Documents) Rules; Publication short form as dies induciae — service and notice requirements; Assumption of agency by legal practitioners.
14 March 2016
Failure to decide a dispositive preliminary procedural point and to give reasons vitiates a judgment and warrants remittal.
Administrative law — Procedural propriety of judicial review applications — Distinction between Order 33 and Order 32/r 226 — Duty to decide dispositive preliminary points — Requirement to give reasons for tacit acceptance — Failure to decide preliminary issue vitiates order — Remittal.
11 March 2016
Appeal dismissed: no admissible fresh evidence, no security under r66, no bona fide defence, prior Supreme Court decision dispositive.
Civil procedure – Summary judgment – High Court Rules r66/r68/r69 – security to satisfaction of Registrar – bona fide defence; Appeal – adducing further evidence on appeal – supplementation of record; Finality of litigation – prior Supreme Court decision; Costs – scale and de bonis propriis.
11 March 2016
A notice of appeal omitting the relief sought is not substantially compliant with Form LC3 and can be struck off the roll.
Labour Court procedure — Notice of appeal (Form LC3) — requirement to state determination appealed and relief sought — substantial compliance — rule 37 improvisation limited — s49 Labour Act discretion subject to prescribed procedures — condonation of fatal defects.
8 March 2016
A deregistered trade union loses capacity to sue; successor must apply for substitution before prosecuting former union’s claims.
Labour law — Trade union deregistration — Effect on corporate capacity to sue or be sued under s29(2) Labour Act — Proceedings by non-existent entity are nullity — Successor union must apply for substitution to claim rights.
7 March 2016
Domicilium clause and clear admission of debt defeated rescission; appeal dismissed with costs.
Civil procedure – rescission of default judgment – good and sufficient cause – domicilium citandi et executandi – valid service – acknowledgement of debt – bona fide defence – appellate interference with discretion.
4 March 2016
Informal assignment not a s14 secondment; court awarded appellant allowance arrears for Oct–Dec 2009.
Public Service Regulations s14 — secondment; whether appointment to run another institution amounts to release to an approved service; implied contract and conduct of parties; entitlement to allowance arrears.
4 March 2016
February 2016
Failure to lift a suspension after acquittal is not automatically an unfair labour practice; reinstatement under s 6(2)(b) differs from reinstatement after dismissal.
Labour law – suspension v dismissal – meaning of reinstatement under s 6(2)(b) of the Labour (National Employment Code of Conduct) Regulations – discretionary refusal to lift suspension – damages in lieu of reinstatement arise in dismissal cases, not suspension disputes.
25 February 2016
A rescission order made after the decision cannot be adduced as further evidence on appeal; further evidence must have existed when the decision was made.
Civil procedure – Appeal – Further evidence – Border Syndicate criteria – Evidence must have existed or been obtainable at time trial decision – Rescission made after judgment not admissible; Arbitration – Registration of arbitral award – Interim suspension by Labour Court – Jurisdiction to suspend enforcement pending appeal.
23 February 2016
Host State allowed to vindicate international organisation’s immunity; condonation granted for late appeal.
Civil procedure – condonation for late appeal; locus standi of host State to vindicate international organisation’s immunity; constitutional effect of treaties and international customary law (s 326(2), s 327(6)); FAO Headquarters Agreement and UN Convention confer immunity from suit, process and execution; stay rendered moot by payment under garnishee.
16 February 2016
Whether disciplinary proceedings were before a properly constituted disciplinary authority and whether damages may be awarded without evidence.
Labour law – disciplinary authority v disciplinary committee – interpretation of National (Employment) Code definitions and s 6(4)(b) – constitution and validity of disciplinary proceedings – award and quantification of damages – requirement for evidence on liability and mitigation.
15 February 2016