Supreme Court of Zimbabwe - 2022

52 judgments
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52 judgments
Citation
Judgment date
November 2022
18 November 2022
17 November 2022
14 November 2022
October 2022
Fixed‑date non‑payment (mora ex re) allows landlord to cancel lease without 15‑day notice; eviction upheld, monetary awards set aside.
Lease cancellation – construction of breach clause – disjunctive ‘or’ – mora ex re for fixed-time rent defaults – landlord entitled to cancel without 15‑day notice; eviction upheld; arrear rent and holding‑over awards set aside for lack of proof; no concluded compromise.
25 October 2022
6 October 2022
Interim caveat granted for alleged tacit universal partnership; final urgent interdict set aside for procedural irregularity.
Civil procedure – urgent chamber application – interim interdict pendente lite – requirements: prima facie right, apprehension of irreparable harm, balance of convenience – tacit universal partnership pleaded – choice of law (customary v general law) not determinative for interim relief – error in granting final relief in urgent proceedings; caveat pendente lite ordered.
3 October 2022
September 2022
Appellant rebutted statutory presumption of intent; conviction for criminal abuse of office set aside due to lack of mens rea.
Criminal abuse of office – mens rea (intention) – reverse onus under s 174(2) – burden to rebut presumption on balance of probabilities – actus reus must be proved beyond reasonable doubt; detention powers under s 201 Customs and Excise Act; material inconsistencies in State evidence undermining inference of malice.
30 September 2022
Where parties split a church, property rights depend on adherence to the constitution, not allegiance or numerical majority.
Church disputes — Secession and schism — Adherence to church constitution and canons determines entitlement to property — Majority or allegiance to leader not determinative — Court bound by pleadings; cannot decide unpleaded causes.
29 September 2022
Whether a Master must conduct an independent 'due inquiry' and, where appropriate, hear beneficiaries before consenting to private estate sales.
Administration of estates – s 120 Administration of Estates Act – 'due inquiry' by Master before consenting to private treaty sale – scope of inquiry – duty to act lawfully, reasonably and fairly under Administrative Justice Act – right to be heard – costs and de bonis propriis.
26 September 2022
July 2022
A live registered mark bars registration of confusingly similar marks despite intervening non-use by the proprietor.
Trade marks — lapse/non-use vs. registered rights — effect of an existing registered mark (172/99) — prohibition on registration of confusingly similar marks (s14(1)(a)) — Registrar's finding of prior goodwill upheld.
29 July 2022
High Court property distribution set aside and remitted for rehearing due to trustees' non-joinder (procedural gross irregularity).
Family law — Matrimonial property distribution (s 7 Matrimonial Causes Act) — Trust assets and company share acquisitions — Trust law — Joinder of trustees and interested parties — Non-joinder as gross irregularity — Supreme Court Act s 25 review powers.
29 July 2022
Court upheld piercing of the corporate veil in interpleader proceedings where the appellant was the company’s alter ego.
Company law – Separate legal personality – Piercing/lifting the corporate veil where fraud, dishonesty or manifest injustice exists – Companies Act s 318(1) – Interpleader proceedings may include consideration of veil-piercing – Alter ego doctrine – Execution/attachment of property in satisfaction of judgment.
29 July 2022
Waiver by conduct can override a non-variation clause; agent-company not liable; damages awarded on valuator's depreciated replacement cost.
Contract law – non-variation clause and waiver by conduct; agency and corporate veil – disclosed principal; assessment of credibility – limits of reliance on demeanour; valuation evidence – depreciated replacement cost admissible and capable of supporting damages; remedial amendment of trial court order on appeal.
29 July 2022
Occupier dismissed from employment had no right of retention; rei vindicatio and eviction upheld, appeal dismissed.
Property law — Actio rei vindicatio — Ownership and unlawful occupation; Employment-related occupation — right of retention; Compromise agreements — proof and denial; Appellate review — deference to trial court factual findings; Preliminary points in limine — scope on remittal.
20 July 2022
A conciliator’s misdescription and initial omission of claimants did not render arbitral proceedings void; matter remitted for rehearing.
Labour law – arbitration – misdescription of party in conciliator’s reference – miscitation amendable where real party identifiable; arbitral procedure – joiner of multiple claimants – arbitrator’s discretion and terms of reference; nullity – wrongful nullification by court; reinstatement v. damages not decided.
14 July 2022
An offer letter does not permit self-help occupation; spoliation restores prior peaceful possession.
Property law – Spoliation (mandament van spolie) – peaceful and undisturbed possession – unlawful dispossession – offer letters and gazetted/acquired land – no self-help – Gazetted Land (Consequential Provisions) Act – restoration of status quo ante.
8 July 2022
June 2022
9 June 2022
A court may not set aside an arbitral award based on post‑award allegations not raised in the founding affidavit.
Arbitration — setting aside award — reasonable apprehension of bias — application stands or falls on founding affidavit — post-award opposing affidavit inadmissible to supplement founding allegations — contradiction in judicial findings — remittal to another arbitrator not determined.
2 June 2022
May 2022
Appeal dismissed: supply agreement binding via ostensible authority; alleged breaches of local statutes unproven, contract enforceable.
Company law – ostensible (apparent) authority and estoppel; Contract law – choice of law upheld; International sale/supply agreements; Severability and Turquand rule; Exchange control and competition statutory defences unproven; Public policy and sanctity of contract.
30 May 2022
Appeal dismissed as moot; Supreme Court refused on-appeal declaratur and declined to entertain procedural challenge to judicial referral.
Judicial discipline — s 187(3) Constitution vs Judicial Service (Code of Ethics) SI 107/2012 — procedural routes; Mootness doctrine — discretion to hear moot appeals; Declaratory relief — Supreme Court lacks original jurisdiction to grant a declaratur.
30 May 2022
Appellant bound by supply contract: ostensible authority, choice of law respected, statutory breaches unproven; appeal dismissed.
Contract law — ostensible (apparent) authority; Turquand rule; choice of law in international contracts; severability/amendment clause; Competition Act; Exchange Control Regulations; estoppel; public policy; enforcement of international commercial obligations.
24 May 2022
Appeal struck off for failure to obtain statutory leave to sue a liquidator; adverse higher-scale costs awarded.
Insolvency law – requirement of leave to sue a liquidator – interlocutory orders – s 43(2) High Court Act – appealability – costs on legal practitioner and client scale for repeated non-compliance.
23 May 2022
Statutory price/duty changes did not apply to fuel already sold; seller could not recover increased duty and purchaser entitled to delivery.
Statutory instruments — retrospectivity — petroleum pricing and customs duty; Customs and Excise Act s 230(1) — prerequisites for recovery of increased duty; Contract law — constitutum possessorium and transfer of ownership; Tacit/implied terms — delivery timelines; Civil procedure — plea cannot confer affirmative relief without counterclaim.
12 May 2022
April 2022
Condonation refused where applicant deliberately abandoned a timely appeal, provided an unsatisfactory explanation, and delayed finality of litigation.
Civil procedure — Condonation and extension of time to appeal — Inordinate delay and deliberate abandonment of appeal — Unsatisfactory explanation — Prospects of success not decisive — Interest in finality — Costs on legal practitioner and client scale.
7 April 2022
An urgent stay application was dismissed as moot because a lawful eviction had already been executed and the applicants’ return constituted contempt.
Urgent chamber application — stay of execution pending condonation application — eviction order — whether matter overtaken by events — effective execution by Messenger of Court — return to premises and contempt — self‑created urgency.
6 April 2022
March 2022
RBZ’s refusal to authorise foreign-currency obligations was a supervening impossibility; arbitral award did not offend public policy.
Arbitration — Article 34 Arbitration Act — setting aside arbitral award — public policy — narrow test; contract — suspensive condition and exchange control approval — supervening impossibility/force majeure; pacta sunt servanda and limits to judicial intervention in arbitration.
29 March 2022
Whether the High Court retains jurisdiction over a chieftainship dispute begun before section 283 took effect.
Constitutional law — Section 283 (traditional leaders) — Transitional provisions — Sixth Schedule para 18(9) — Retrospective effect — High Court original jurisdiction over pending chieftainship disputes.
29 March 2022
25 March 2022
Delictual claims in USD are not payable at statutory parity unless converted to judgment debts before the cut‑off date.
Reserve Bank Act ss 22 & 20 — Currency conversion — One-to-one parity applies to assets, liabilities and judgment debts extant on or before cut-off date — Delictual claims not assets/liabilities until adjudicated — Zambezi Gas limited to judgment debts.
24 March 2022
Spoliation can restore possession despite temporary cessation of physical activity; urgency and spoliation characterisation upheld.
:[
23 March 2022
The respondent’s proof of payment and allocation sufficed to establish a clear right for a final interdict.
Interdicts — requirements for final interdict: clear right, irreparable harm, absence of alternative remedy; clear right may be established by proof of payment and allocation without registered title. Double allocation/lease conflict — purchaser’s accepted payment and allocation letters limit local authority’s power to lease. Eviction vs interdict — interdict proper where prohibition of unlawful occupation and development is sought.
22 March 2022
21 March 2022
February 2022
Appeal court held absolution was wrongly granted and unpleaded reconventional relief improperly awarded; matter remitted for trial continuation.
Civil procedure – absolution from the instance – test for prima facie case; Evidence – credibility findings should not be made before defendant gives evidence; Civil procedure – reconvention – court cannot grant relief not pleaded; Security documents – validity of suretyships and mortgage bonds to be determined at full hearing.
25 February 2022
A court must consider prospects and prejudice, not only delay, before dismissing for want of prosecution.
Civil procedure – dismissal for want of prosecution – court must consider delay and explanation, prospects of success on merits, and balance of convenience/prejudice (Guardforce). Failure to consider all factors is a material misdirection permitting interference on appeal.
24 February 2022
A Labour Officer lacks jurisdiction to conciliate matters already determined internally; ensuing arbitration and court proceedings were set aside.
Labour law – jurisdiction of Labour Officer under s 93 – referral under s 8(6) of National Employment Code – internal disciplinary determination precludes Labour Officer intervention – arbitration and Labour Court proceedings arising from irregular conciliation are invalid – review under s 25(1) Supreme Court Act.
24 February 2022
Article 16(3) bars late challenges to jurisdictional rulings; interlocutory awards on prescription are challengeable under Article 34.
Arbitration — Model Law Articles 16(3) and 34 — Distinction between tribunal “ruling” on jurisdiction and “award” — Article 16(3) thirty‑day limit exclusive for jurisdictional rulings — interlocutory/interim awards (prescription) challengeable under Article 34.
24 February 2022
Appeal against striking off rescission application is a nullity without leave; appeal against discharge of provisional interdict is valid (not a consent order).
Civil procedure — Appealability — Consent orders — parties cannot appeal orders made with their consent; Interlocutory orders — leave required under s 43(2)(d) High Court Act; Authority to litigate — absence of board resolution/founding affidavit renders company application a nullity and appeal invalid without leave; Notice of appeal — defective/‘incurably bad’ appeals must be struck off.
22 February 2022
Applicant improperly sought final cancellation of title via urgent provisional application and failed to meet required standards.
Civil procedure – Interdicts – Distinction between provisional (interim) and final orders – Provisional orders preserve status quo on prima facie basis; final orders require proof of clear right – Granting final relief in urgent proceedings exceptional – Framing of relief and alternative interim measures (temporary interdict) – Urgency and locus standi – Protection of innocent purchasers.
15 February 2022
Registrar erred in dismissing the applicant's condonation application for delayed filing of proof of service; service (not the certificate) must be within three days.
Procedure — Review of Registrar’s decision under r 13 — Interpretation of r 43(4) (service within three days) — Distinction between service and filing proof of service — r 39(2) generally applicable; r 43 dominant where conflict — Access to justice and reasonable time for filing certificate of service.
9 February 2022
Appellant may not deduct US$10 million paid on behalf of its holding company; appeal dismissed with costs.
Tax law; deductibility of donations; separate legal entity; indigenisation obligations; expenses incurred by related companies; non-retroactivity of tax amendments; capital v. revenue expenditure.
3 February 2022
An appeal struck off as fatally defective (vague grounds, lack of heads) cannot be reinstated; proper remedy is condonation/fresh appeal.
Civil procedure — Reinstatement of appeal — Rule 70 Supreme Court Rules (2018) — Practice Direction 3/13 para 5 — Struck off the roll — Fatally defective appeal — Vague/prolix grounds of appeal — Condonation and extension as appropriate remedy — Costs on attorney and client scale.
1 February 2022
Condonation refused: High Court lacked statutory power to register trusts; rescission under r449 valid and appeal prospects poor.
Procedural law – chamber/ex parte applications and appeals without a cited respondent; High Court Rules r 449(1)(a) – rescission of orders granted in absence of an affected party; Deeds Registries Act – exclusive statutory power of Registrar of Deeds to register and certify trusts; condonation for late noting of appeal – delay, explanation and prospects of success; capacity of trusts to sue – must be represented by trustee and founding affidavit by trustee.
1 February 2022
Application for condonation and extension dismissed: delay unexplained, prospects weak, and acceptance of terminal benefits amounted to waiver.
Civil procedure – condonation and extension of time to appeal – r 61 Supreme Court Rules – interplay with Prescription Act – conciliation, draft ruling and confirmation under Labour Act – procedural compliance (Isoquant) – waiver by acceptance of terminal benefits.
1 February 2022
Where Labour Court refuses condonation, s92F(3) allows chamber application for leave to appeal, but vague grounds render application a nullity.
Labour law — s92F(2)–(3) Labour Act — leave to appeal to Supreme Court after Labour Court refuses condonation — chamber application to Supreme Court judge; appellate procedure; condonation; defective grounds of appeal; nullity; costs.
1 February 2022
January 2022
A court may not grant final interdicts on a prima facie case; the electoral commission has corporate personality and should be sued in its name.
Civil procedure – interdicts – interim (provisional) vs final interdicts – evidential thresholds: prima facie right for provisional relief vs clear right on balance of probabilities for final relief; Courts must not grant final relief in urgent proceedings without return date where only prima facie case established. Electoral law – citation and joinder of electoral commission – inconsistency between Electoral Act s14 and s4A and Constitution s319; electoral commission is a body corporate capable of being sued in its own name.
31 January 2022
27 January 2022
25 January 2022
Arbitrator exceeded compulsory-arbitration terms of reference; no enforceable employment contract found against the second respondent.
Labour law – compulsory arbitration – terms of reference – arbitrator confined to terms of reference and must not determine matters beyond them; Arbitration – making contracts for parties impermissible; Employment law – enforceability of contracts and proof of existence of an employer-employee contract; Appellate review – deference to factual findings unless grossly unreasonable.
24 January 2022
Disallowance of consumables/prepayments; deductions for royalties and inventory revaluation upheld; technical services remitted for s98 inquiry.
Income tax – deductibility – s 15(2)(a) – matching of expenses to income year – consumables – statutory prepayments – royalties/trademarks – administrative ratification – technical services – s 98 tax avoidance inquiry – inventory revaluation – penalties and interest.
18 January 2022
Whether a dollar‑denominated loan is a "foreign obligation" excluded from statutory conversion to RTGS dollars at par.
Banking and finance law – Deeming provisions under S.I.33/2019 and Finance (No.2) Act – Whether a dollar‑denominated loan is a "foreign obligation" excluded from conversion to RTGS dollars – evidence and factual matrix critical to classification.
18 January 2022