Court of Appeal of Tanzania

This is the highest level in the justice delivery system in Tanzania. The Court of Appeal draws its mandate from Article 117(1) of the Constitution of the United Republic of Tanzania. The Court hears appeals  on both point of law and facts for cases originating from the High Court of Tanzania and Magistrates with extended jurisdiction in exercise of their original jurisdiction or appellate and revisional jurisdiction over matters originating in the District Land and Housing Tribunals, District Courts and Courts of Resident Magistrate. The Court also hears similar appeals  from quasi judicial bodies of status equivalent to that of the High Court. It  further hears appeals  on point of law against the decision of the High Court in  matters originating from Primary Courts. The Court of Appeal also exercises jurisdiction on appeals originating from the High Court of Zanzibar except for constitutional issues arising from the interpretation of the Constitution of Zanzibar and matters arising from the Kadhi Court.

Physical address
26 Kivukoni Road Building P.O. Box 9004, Dar Es Salaam, Tanzania.
43 judgments

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43 judgments
Citation
Judgment date
September 2019
Failure to file required appeal documents within 60 days (without delay certificate) leads to the Notice of Appeal being struck out.
Court of Appeal — Civil appeals — Notice of appeal insufficient alone — Rule 90(1) requires memorandum and record in quintuplicate and security for costs within 60 days — failure to take essential steps — Rule 89(2) strike out — Rule 91(a) deeming withdrawal.
30 September 2019
Notice of appeal struck out for failure to file memorandum, record and security within 60 days; deemed withdrawn under Rule 91(a).
Civil procedure — Appeals — Notice of appeal vs institution of appeal — Rule 90(1): requirement to file memorandum of appeal, record of appeal and security for costs within 60 days — Certificate of delay — Rule 91(a): deemed withdrawal for failure to take essential steps — Rule 89(2): striking out notice for failure to prosecute.
30 September 2019
The appellant's dismissal for an alleged unlawful assembly was unfair; CMA delay and mediator referral did not invalidate the award.
* Labour law – unfair termination – alleged unauthorised assembly/strike – burden to prove unlawful assembly; * Labour procedure – mediation to arbitration referral – no codified procedure; parties' recorded consent sufficient; * Employment and Labour Relations Act s.88(9) – delay in delivering award (beyond 30 days) not automatically fatal absent prejudice.
30 September 2019
Inadequate summing up to assessors rendered the trial a nullity; convictions quashed and retrial ordered.
* Criminal procedure – trial with assessors – duty of judge to adequately sum up to assessors on vital points of law (s.298(1) CPA) – inadequate summing up renders trial a nullity. * Criminal law – murder – ingredients of offence and application of doctrine of recent possession – assessors must be directed on these points. * Evidence – extra-judicial/confessional statements – effect of retracted confessions and necessity to direct assessors on their probative value. * Appellate relief – nullification of trial, quashing of convictions and sentences, and ordering of retrial before another judge and different assessors.
30 September 2019
Failure to consider the accused’s defence and not reading an admitted PF3 vitiated the conviction.
Criminal law – Unnatural offence; documentary exhibits (PF3) must be read and explained when admitted; courts must objectively consider accused’s defence (including alibi) even if no prior notice given; failure to consider defence vitiates conviction; conviction and sentence quashed; release ordered.
30 September 2019
Court affirmed convictions: cautioned statements admissible, voluntary, and circumstantial evidence proved guilt beyond reasonable doubt.
Criminal law – circumstantial evidence; admissibility and timing of cautioned statements under sections 50 and 51 CPA; exclusion of transfer time under section 50(2)(a); voluntariness of confessions; relevance of information leading to discovery (s.31 Evidence Act); pre-determination of guilt.
30 September 2019
High Court erred by dismissing extension applications without considering good cause, denying appellants a fair hearing.
Criminal procedure – extension of time to file appeal – section 361(2) CPA – requirement to show good cause; Judicial overreach – predetermining merits of appeals not before the court; Right to fair hearing – Article 13(6)(a) – breach where court fails to consider applicants' reasons; Remedy – nullification of proceedings and order to permit fresh applications; Distinction – striking out v dismissal and respective consequences.
30 September 2019
30 September 2019
Second appeal upheld conviction; defective charge curable, but thirty-year sentence substituted with mandatory life imprisonment.
Criminal law — second appeal — limits on raising new grounds; evidence — child complainant credibility and medical corroboration (PF3); charge sheet defects — omission of statutory subsections curable under s.388 CPA when particulars clear; procedure — timing of charge after arrest not fatal; sentencing — mandatory life imprisonment under s.154(2) where victim under 18.
30 September 2019
Victim's credible identification upheld; rape proved beyond reasonable doubt despite delayed medical report and no identification parade.
* Criminal law – Sexual offences – Rape – Victim as primary witness – identification where victim knew accused – reliability of identification. * Medical evidence – PF3 – delayed examination – evidential value not decisive; medical proof not indispensable. * Identification parade unnecessary where victim knew suspect prior to offence.
30 September 2019
Illiterate maker's s34B statement expunged, but conviction upheld on remaining admissible confessional evidence.
* Evidence Act s.34B – admissibility of written statements where maker is not called – cumulative compliance with s.34B(2)(a)-(f) and special requirement for illiterate makers. * Extra-judicial confessions – voluntariness and timing – no strict statutory time limit; voluntariness is determinative; Chief Justice’s instructions to Justices of the Peace must be observed. * Cautioned statements – improperly witnessed cautioned statements may be rejected and, if expressly discarded by trial judge, do not necessarily infect the conviction. * Appellate review – late objections to admissibility not raised at trial are ordinarily untenable, but courts will correct clear statutory non-compliance on first appeal.
30 September 2019
Failure to record the child's statutory promise vitiates her testimony, but corroborative evidence can still sustain conviction.
* Evidence Act s.127(2) (as amended) – child of tender age must promise to tell the truth; omission is fatal. * Rape – medical/ PF3 evidence persuasive but not binding; victim’s oral evidence primary. * Admissibility of cautioned statement – voluntariness and reading in court. * Corroboration – admission to independent witnesses can corroborate confession and sustain conviction. * Appeal procedure – new grounds not raised in first appeal ordinarily not entertained.
30 September 2019
Review application dismissed for lack of manifest error; applicant failed to substantiate service with affidavit, appeal remained time-barred.
* Civil procedure – Review jurisdiction under Rule 66(1)(a) – manifest error on the face of the record required to be obvious and self-evident. * Service of documents – party relying on service must produce affidavit of material witness who received the documents. * Review vs appeal – factual disputes and re-examination of credibility cannot be resolved by review; would amount to appeal in disguise. * Time bar – failure to comply with mandatory service requirements can render an appeal hopelessly out of time.
27 September 2019
Failure to consider the appellant's defence rendered the conviction unsafe; appeal allowed and appellant released.
Criminal law – evaluation of evidence – duty of trial and first appellate courts to consider defence evidence – failure to weigh defence vitiates conviction; mental fitness to stand trial; evidence sufficiency and identification issues.
27 September 2019
Appellant's constitutional right to be present and heard on appeal was breached; appellate proceedings nullified and remitted for rehearing.
* Criminal law – Appeal – Right to be heard – Article 13(6)(a) Constitution – Determination of appeal in appellant's absence without proof of service renders proceedings a nullity. * Criminal procedure – Competence of memorandum of appeal – Section 362(2) Criminal Procedure Act – Defective written submissions cannot be cured by dismissing appeal in absence of appellant. * Appellate jurisdiction – Revision power – Section 4(2) Appellate Jurisdiction Act – Nullification and quashing of appellate proceedings and remittal for rehearing.
26 September 2019
Uncorroborated recognition evidence failed to prove arson and assault; convictions quashed and sentences set aside.
* Criminal law – Identification evidence by recognition – caution required; uncorroborated recognition may be unreliable * Arson – Elements: willful unlawful setting of fire; need to prove opportunity, access or preparation when evidence is circumstantial * Evidentiary standards – Circumstantial evidence must exclude reasonable hypotheses of innocence * Criminal procedure – Particulars in charge sheet – omission of specific sub‑section not fatal if particulars otherwise give sufficient notice * PF3/medical evidence – absence of direct testimonial link weakens proof of assault causation
25 September 2019
Appellant’s conviction for uttering forged documents upheld where evidence proved forgery and his knowledge to defraud.
* Criminal law – Forgery and uttering false documents – Proof of forgery by tampering with voucher numbers and removal of cheque leaves – Knowledge and intent to defraud inferred from presentation of forged documents. * Evidence – Weight of bank and council officers’ testimony in establishing forgery. * Sentencing – Legality of maximum sentence imposed by a Senior Resident Magistrate.
24 September 2019
Conviction quashed where confession and documents were improperly admitted, defence ignored, and possession was not adequately proved.
* Evidence — Confession — Mandatory inquiry (trial within trial) upon objection to confession — section 27(2),(3) Evidence Act. * Evidence — Documents — requirement to read admitted exhibits aloud; failure renders exhibits of no evidential value. * Criminal law — Possession of suspected stolen property — necessity for independent corroboration of arresting officer’s testimony. * Criminal procedure — Substitution of charge under section 306(1) Criminal Procedure Act permissible but requires sufficient supporting evidence. * Fair hearing — Duty to consider defence evidence; omission vitiates conviction. * Retrial — Ordered only if in interests of justice; insufficiency of evidence and time already served may preclude retrial.
24 September 2019
Commercial Division can hear commercial loan disputes with land elements; default‑notice issues are factual, requiring trial evidence.
Jurisdiction — High Court divisions (Commercial and Land) are parts of the High Court; parties cannot by contract oust statutory jurisdiction; Commercial Division may hear commercial loan disputes with land/security elements; Procedure — questions of service and sufficiency of notice of default are factual issues not ordinarily resolvable on preliminary points of law; Remittal — matter returned to Commercial Division for hearing by another judge.
23 September 2019
A dismissal under Order XVII r.3 CPC is a decree and is appealable as of right under section 5(1)(a) AJA.
Civil procedure — Order XVII r.3 CPC — dismissal for want of prosecution — decision on the merits — decree under s.3 CPC — appealability under s.5(1)(a) AJA — no leave required; precedential conflict resolved in favour of earlier authorities (Salem Ahmed Hasson Zaidi; Ally Khalfan Mleh).
20 September 2019
Whether a trial court's judgment and decree complied with Order XX and whether the appeal should proceed on the merits.
Civil procedure – validity of judgment and decree – compliance with Order XX Rules (4), (5) and Rule 6(1) CPC – whether judgments must decide each framed issue and state reliefs; Appellate jurisdiction – Section 4(2) AJA – scope to revise or quash proceedings for irregularities; procedural point – raising validity of judgment for first time on appeal.
20 September 2019
High Court quashed imprisonment sentence imposed on a 16‑year‑old as unlawful under the Law of the Child Act.
* Child offenders – sentencing – Law of the Child Act s.116(1) – imprisonment not prescribed for children. * Illegality of sentence – imprisonment imposed on a minor – sentence quashed. * Supervisory jurisdiction – High Court visiting prison may call records and revise lower court sentences in interest of justice.
20 September 2019
Unexplained succession of judges during trial vitiates proceedings and warrants nullification and remittal for rehearing.
* Civil procedure – irregular change of presiding judges – individual judge calendar – Order XVIII r.10(1) CPC – unexplained transfers vitiate proceedings; entire proceedings liable to be nullified and remitted for rehearing. * Civil procedure – decree must conform to judgment – Order XX r.7 CPC.
20 September 2019
Application for stay struck out because the impugned decree was declaratory and not executable.
Land law — stay of execution — executability of decree — declaratory orders not executable; title revocation and vesting in the State impede execution; competency of stay application.
20 September 2019
A successor judge's failure to record reasons for taking over a trial is jurisdictional and renders proceedings a nullity.
Civil procedure – succession of judges – Order XVIII r.10(1) CPC – mandatory requirement to record reasons when successor judge takes over; jurisdictional defect – failure to record reasons vitiates proceedings; overriding objective principle cannot cure jurisdictional/mandatory procedural defects; remedy: quash proceedings, set aside judgment and remit for fresh trial.
11 September 2019
Successor judges' failure to record reasons under Order XVIII r.10(1) CPC renders the proceedings a nullity.
* Civil procedure – Succession of judges – Order XVIII r.10(1) CPC – Mandatory requirement to record reasons where a judge is prevented from concluding a trial – failure to record reasons renders proceedings a nullity. * Jurisdiction – Procedural irregularity going to jurisdiction – overriding objective principle cannot cure jurisdictional defects. * Remedy – Quashing of proceedings, setting aside judgment and remitting for fresh trial.
11 September 2019
Failure to read and explain the memorandum at preliminary hearing breaches s192(3) CPA and vitiates the proceedings, requiring a rehearing.
* Criminal Procedure – Preliminary hearing – Compliance with section 192(2) and (3) CPA – memorandum of undisputed facts must be read and explained to accused. * Evidence – Admission of documentary exhibits (PF3) – defence must be afforded opportunity to object or respond. * Procedural law – Failure to comply with mandatory preliminary hearing requirements is a fundamental, incurable irregularity. * Remedy – Nullification/quashing of defective preliminary hearing and order for rehearing from that stage.
10 September 2019
Expiry of probation does not automatically confirm employment; a still‑probationary resigning employee cannot claim ELRA Part III Sub‑Part E remedies.
Employment law — probationary employment — expiry of probation does not automatically confer confirmation; confirmation depends on contractual conditions — entitlement to remedies under Part III Sub‑Part E ELRA limited to non‑probationary employees — right to be heard where issue of probation was litigated in earlier proceedings.
9 September 2019
A probationary employee not confirmed at resignation cannot claim unfair termination under Part III, Sub‑Part E ELRA.
Employment law – Probationary period and confirmation; Rule 10 Code of Good Practice – probation not automatically converted to confirmation; ELRA s.35 – exclusion from Part III Sub‑Part E for employees under probation/with less than protected status; Constructive dismissal – probationers not entitled to unfair termination remedies; Natural justice – right to be heard where issue was previously pleaded.
9 September 2019
Failure to read and take plea to an amended charge nullified the trial; regulation invalidation requires judicial review.
Criminal procedure — Amendment of charge — section 234(2) CPA — mandatory requirement to read altered charge, take plea and allow recall of witnesses; failure renders trial nullity. Administrative law — Subsidiary legislation — regulations made under section 106(1) of the Forest Act can only be challenged by judicial review (Cap. 310); appellate courts must not invalidate regulations sua sponte. Forest law — Possession of imported timber — accused must account for lawful possession; import permit may be obtained post‑importation.
9 September 2019
The applicant's failure to account for each day of delay justified denial of extension to file a reference.
* Civil procedure — Court of Appeal — Reference under Rule 62 — extension of time — requirement to show good cause and account for each day of delay. * Illegality as ground for extension — must be apparent on the face of the record and properly pleaded. * Limitation Act — certain provisions inapplicable to Court of Appeal (s.43(b)). * Full Court interference — only where single Judge misinterprets law or exercises discretion improperly.
9 September 2019
Reference dismissed: applicant failed to account for delay and alleged illegality was not apparent or pleaded.
Court of Appeal — Reference under Rule 62 — Extension of time — Good cause requires accounting for each day of delay — Illegality as ground for extension must be apparent on face of record — Law of Limitation Act provisions inapplicable to Court of Appeal under section 43(b).
9 September 2019
A stay of execution application is premature and incompetent unless accompanied by security and a notice of intended execution.
Stay of execution – Rules 11(3)–(7) Court of Appeal Rules – cumulative conditions for stay – necessity of security or firm undertaking (Rule 11(5)(c)) – requirement to attach notice of intended execution (Rule 11(7)(d)) – prematurity where application relies on hearsay; failure to comply is fatal.
9 September 2019
An application for stay of execution is premature if the applicant fails to furnish security and attach the notice of intended execution.
* Civil procedure – Stay of execution – Rule 11(3)–(7) – cumulative compliance required; security (Rule 11(5)(c)) mandatory; copy of notice of intended execution (Rule 11(7)(d)) required; application based on hearsay is premature.
9 September 2019
Failure to read and explain the memorandum of undisputed facts to the accused vitiated the preliminary hearing; proceedings nullified and remitted.
Criminal procedure – Preliminary hearing – Memorandum of matters agreed – Requirement to read over and explain memorandum to accused under s.192(3) Criminal Procedure Act – Mandatory duty; Failure to comply vitiates proceedings – Remedy: nullification under s.4(3) Appellate Jurisdiction Act and remittal; Transfer order vacated.
9 September 2019
High Court improperly decided an unpleaded ownership dispute after the underlying eviction order was quashed.
Land law – execution of court orders; scope of suit founded on eviction order – court may not decide unpleaded ownership dispute suo motu; admissibility and evidential value of documents annexed to pleadings; prior civil proceedings that neither adjudicated ownership nor granted title do not vest ownership.
5 September 2019
Extension of time refused where delay was unexplained and alleged illegality was not apparent on the record.
* Civil procedure – extension of time – applicant must show good cause under Rule 10 and Lyamuya factors (length of delay, reasons, diligence, prejudice, apparent illegality). * Probate/inheritance dispute – allegations of illegality in distribution orders must be apparent on the face of the record to justify extension. * Procedural compliance – notice of motion and supporting affidavit are complementary; minor defects are curable and not necessarily fatal.
5 September 2019
Applicant failed to show good cause or apparent illegality to justify an extension of time to file a revision application.
* Civil procedure – Extension of time (Rule 10) – Good cause required – Lyamuya factors (length and reasons for delay, diligence, prejudice, point of law/illegality apparent on record). * Procedure – Form of application (Rule 48(1)) – Notice of motion and affidavit complementary; minor defects curable; expungement of argumentative paragraphs. * Illegality as basis for extension – must be apparent on face of record, not one requiring lengthy argument or research.
5 September 2019
Extension granted where delay excused by bona fide pursuit of appeal and alleged manifest illegalities justified revision.
Extension of time – Rule 10 Court of Appeal Rules – good cause – pursuing appeal and refusal of leave – excusable delay; Revision v. appeal – single Justice not to pre‑judge merits; Alleged illegality apparent on face of record (assessors, succession of Judge, recall of witness, mediation irregularity) justifies extension.
4 September 2019
High Court erred by deciding ownership sua sponte after the eviction order central to the suit had been quashed.
Land — Execution of eviction order — Eviction order quashed — Trial court improperly deciding ownership sua sponte — Parties entitled to be heard on newly raised issues — Documents annexed to pleadings require formal tender to have evidential value — Prior civil proceedings failing to vest title do not establish ownership.
3 September 2019
Applicant granted conditional stay pending appeal subject to depositing TZS 16,200,700 bank guarantee within 45 days.
Stay of execution – Rule 11(2) Court of Appeal Rules – requirement of no unreasonable delay and demonstration of substantial loss – firm undertaking for security suffices – conditional stay on bank guarantee.
2 September 2019
Court granted 60-day extension to file revision due to apparent illegality in High Court proceedings despite applicant's delay.
Civil procedure – extension of time under Rule 10 – applicant’s failure to account for each day of delay – counsel’s negligence – illegality apparent on face of record as sufficient cause – summary rejection/misinterpretation of procedural rules by High Court.
2 September 2019
Reported
An apparent illegality on the face of the record justified a 60‑day extension despite applicants' delay and counsel's negligence.
Extension of time – Rule 10 Court of Appeal Rules – requirement to account for each day of delay – diligence of counsel – illegality apparent on the face of the record as sufficient cause – striking out for want of prosecution – misinterpretation of law (Order IX r.9(1) CPC) – grant of 60 days extension; costs each party.
2 September 2019