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.
759 judgments

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759 judgments
Citation
Judgment date
July 2021
Applicant failed to prove the appeal was withdrawn by fraud or mistake; restoration denied and application dismissed.
Criminal procedure – restoration of withdrawn appeal under rule 77(3) – requirements: withdrawal induced by fraud or mistake and interests of justice; Evidence – burden on applicant to prove withdrawal by fraud or mistake with supporting evidence; Procedural relief – consequential orders dependent on successful restoration of appeal.
15 July 2021
Night-time visual identification by moonlight was unsafe; convictions quashed and appellants released.
Criminal law – Robbery with violence – Visual identification at night by moonlight; reliability and Waziri Amani factors; single-witness evidence; need for corroboration; adverse inference for omission to call available witnesses; failure to connect arrests to charged offence.
14 July 2021
Failure to serve the written request for certified High Court proceedings invalidated the certificate of delay; appeal was time-barred and struck out.
Civil procedure – Appeals – Time limit for instituting appeal – Rule 90(1) & (3) Tanzania Court of Appeal Rules – Certificate of delay; requirement that application for certified proceedings be in writing and served on respondents – Failure to serve invalidates certificate – Jurisdictional nature of sixty-day rule – Overriding objective cannot cure mandatory procedural defects.
14 July 2021
Seven‑year delay and unsubstantiated record‑tampering claims failed to show good cause for extension to seek revision.
Extension of time — Rule 10 Court of Appeal Rules — good cause and Lyamuya guidelines; inordinate delay; revision versus appeal — revisional jurisdiction not alternative where appeal remained available; alleged illegality/tampering must be apparent on face of record; counsel’s mistake and change of advocate not good cause.
14 July 2021
A court’s suo motu decision on limitation without hearing parties violates the right to be heard and renders the judgment null.
Civil procedure – right to be heard (audi alteram partem) – court raising and deciding limitation suo motu while composing judgment without affording parties opportunity to address – such judgment a nullity. Constitutional law – natural justice – right to be fully heard as fundamental right. Appellate jurisdiction – revisional powers – nullification and remittal for rehearing.
14 July 2021
Victim’s credible evidence and medical corroboration upheld rape conviction; charge‑sheet defect cured and appeal dismissed.
Criminal law – Rape of a child – Evidence of victim under age eight – penetration and identification as primary proof. Criminal procedure – Defective charge sheet – omission of statutory subsection curable under s.388 CPA where particulars give sufficient notice. Appeals – Second appeal jurisdiction – new grounds not raised in first appeal are inadmissible. Evidence – Corroboration and medical examination as supporting proof; alibi failing to discharge burden.
14 July 2021
Court dismissed appeal, holding child’s sworn testimony and mother’s independent inspection sufficed for conviction.
Criminal law – Evidence of child witness – Voire dire: once a child understands oath and duty to speak truth, no separate intelligibility test required. Evidence – Child witness credibility – Unsuspended credible child testimony may suffice for conviction under section 127. Evidence – Parent's non‑expert inspection – A parent may give eyewitness evidence of physical signs without being an expert and can corroborate a child witness. Criminal procedure – Alibi – Where prosecution establishes accused's presence, unsupported alibi is insufficient. Appellate procedure – New factual grounds not raised below are not entertainable by the Court of Appeal.
13 July 2021
Trial nullified for inadequate summing up on malice aforethought and alibi; retrial ordered.
Criminal procedure – Duty to authenticate witness testimony – presiding judge must append signature at end of a witness's testimony (after all stages of examination and any judicial/assessor questions). Criminal procedure – Trials with assessors – mandatory duty to sum up and explain vital points of law to assessors, including malice aforethought and alibi; failure renders trial unfair and a nullity. Remedy – retrial before a new judge and different assessors.
13 July 2021
Second‑appeal allowed: child identification and procedural defects rendered conviction unsafe; judgment and sentence quashed.
Evidence — Child witness — compliance with section 127(2) Evidence Act — promise to tell truth as substantial compliance. Criminal procedure — substitution of charge — duty to inform accused of right to recall witnesses; triviality where amendment merely corrects date. Criminal procedure — succession of magistrates — pretrial participation does not invoke section 214(1) requirements where one magistrate conducted trial. Practice — reminding accused of charge before defence is not a legal requirement. Evidence — documentary exhibits must be read out in court; failure is fatal — exhibit expunged. Identification — visual identification by a child must eliminate all reasonable possibilities of mistaken identity; failure to call material witnesses and improperly rejecting alibi renders conviction unsafe.
13 July 2021
Failure to read admitted documentary exhibits to the accused is fatal, warranting expungement and quashing of conviction.
Criminal procedure – Documentary exhibits must be cleared, admitted and read over to the accused; failure to read admitted exhibits is fatal – Expungement of exhibits – Sufficiency of remaining oral evidence to prove possession of Government Trophy – Revisional powers under s.4(2) AJA to quash conviction and set aside sentence.
12 July 2021
Refusal to waive one‑third deposit for filing an objection is not appealable to the Tax Appeals Board; appeal dismissed.
Tax law – Appealability – Whether refusal to waive the one‑third deposit for lodging an objection is a tax or objection decision appealable to the Tax Appeals Board; statutory interpretation (TAA and TRAA) – ejusdem generis and literal approach; jurisdiction of Tax Appeals Board; Rule 6 and limits on appealable decisions.
9 July 2021
Failure to take a plea to an amended charge vitiated the trial; conviction quashed and no retrial ordered; appellant released.
Criminal procedure – Amendment of charge – Mandatory requirement to call accused to plead to new/altered charge under section 234(2)(a) – Failure renders trial a nullity. Evidence – Identification – Dock identification and identification parade – requirements and consequences of improper handling/absence of proper description. Retrial – Application of Fatehali Manji criteria – retrial not ordered where prosecution evidence has material weaknesses and retrial would risk injustice. Revisional powers – Court of Appeal invoking section 4(2) AJA to nullify proceedings and quash conviction.
9 July 2021
Eyewitness identification in daylight and hot pursuit can sustain armed robbery convictions despite non-production of stolen items.
Criminal law – armed robbery – identification in daylight and hot pursuit; Evidence Act s.143 – prosecution discretion on witnesses; non-production of stolen property goes to weight not admissibility; cautioned statements recorded outside statutory period expunged.
8 July 2021
Retracted confessions need corroboration; actual, not mere constructive, possession proved possession of elephant tusks.
Wildlife offences – unlawful hunting, possession and dealing in government trophy; retracted cautioned statements require corroboration; constructive possession versus actual possession; defective particulars of offence (unlawful dealing) – acquittal; exhibits not read aloud to be expunged; charging under repealed statute is fatal; curable mis-citation of sentencing provision under Wildlife Conservation Act.
8 July 2021
Visual and voice identification, supported by medical and circumstantial evidence, upheld murder convictions and death sentences.
Criminal law – visual identification – application of Waziri Amani safeguards; voice identification – approached with caution but admissible if witness familiar; autopsy report not indispensable where medical and eyewitness evidence prove death and cause; alibi – burden to prove; malice aforethought – established by brutal, premeditated attack (matricide).
8 July 2021
Review dismissed: no patent error or denial of hearing; review cannot be used to re‑argue the appeal.
Criminal procedure – Review under Rule 66(1) – manifest error on the face of the record – post-mortem report anomaly treated as 'slip of the pen' – alleged omission of pages in record of appeal – right to be heard – review is not a rehearing of appeal; finality of litigation.
6 July 2021
Appeal dismissed: identification found reliable, facilitator liable under section 22(1), and 30-year sentence mandatory under section 287A.
Criminal law – armed robbery – visual identification – factors for reliable identification: duration, proximity, lighting, prior acquaintance, immediate mention to police, corroboration. Criminal law – parties to offence – section 22(1) Penal Code – facilitator, abettor or aider treated as principal offender. Appellate jurisdiction – Court will not entertain new grounds not raised/determined on first appeal. Sentence – section 287A(1) mandatory minimum sentence.
5 July 2021
The Tax Appeals Board has exclusive jurisdiction over civil disputes arising from administration of revenue laws, including damages claims.
Tax Revenue Appeals Act s.7 – Board’s sole original jurisdiction over civil proceedings arising from revenue laws; s.7A and s.12 – procedural requirements for tax assessments, not limits on jurisdiction; inclusion of Cap.124 in TRA Act First Schedule; jurisdictional ouster of ordinary courts for revenue-law disputes; relief sought does not determine forum.
5 July 2021
Armed robbery conviction quashed where prosecution failed to prove use of a weapon and recent-possession presumption was rebutted.
Criminal law – Armed robbery – Elements: theft and use of dangerous/offensive weapon – Insufficient proof of weapon vitiates armed robbery; Recent possession – prerequisites and rebuttal by credible explanation; Charge validity – omission of amending Act does not render charge defective (Interpretation of Laws Act s.12(1)).
5 July 2021
Failure to explain vital legal points to assessors rendered the trial a nullity and convictions were quashed due to insufficient evidence.
Criminal procedure — High Court trials with assessors — duty to sum up facts and law to assessors; inadequate summing-up renders trial a nullity; visual identification and identification parade requirements; admissibility and procedural formalities for extra-judicial statements; retrial vs. quashing conviction where evidence insufficient.
5 July 2021
Whether service irregularity and a wrongly dated decree warrant striking out an appeal or allow rectification by supplementary record.
Civil procedure — Preliminary objection — requirement that a preliminary objection raise a pure point of law — factual disputes on service require evidence and cannot be disposed of on objection. Court of Appeal Rules, r.97(1) — duty to serve memorandum and record of appeal within seven days where respondent has given address for service. Decree — must bear date of pronouncement of judgment; discrepancy renders decree defective (Order XXXIX r.35(1) CPC). Overriding Objective (ss.3A–3B AJA) and r.96(7) — Court may allow supplementary record to cure defects rather than striking out appeal.
5 July 2021
Court upheld murder convictions, finding identification reliable and domicile discrepancies immaterial.
Criminal law – Murder – Identification evidence – familiarity with accused, adequate lighting (solar bulbs and moonlight), sufficient observation time – minor inconsistencies not fatal. Post‑mortem report – evidential purpose is cause of death, not domicile. Delay in arrest – explained flight of suspects; delay did not vitiate identification.
5 July 2021
The Court affirmed an eight-year sentence for attempted murder, finding mitigating factors were considered and the term was not excessive.
Criminal law – Attempted murder – sentence – whether eight years imprisonment excessive; consideration of mitigating factors (first offender, youth, guilty plea, time in custody); appellate interference with sentence limited to specific grounds.
5 July 2021
An appeal from a High Court revisional order in a land matter is incompetent without statutory leave and is struck out with costs.
Land law – Appeals from High Court exercising revisional jurisdiction – Requirement of leave under section 47(2) Land Disputes Courts Act. Civil procedure – Revision under section 43(1)(b) LDC Act and section 79 CPC – classification of proceedings as revisional. Appellate jurisdiction – Limits of Court of Appeal’s powers under section 4(2) AJA where appeal is not properly before the Court. Remedy – appeal requiring leave lodged without it is incompetent and should be struck out with costs.
2 July 2021
Appellant allowed to lodge supplementary record to rectify defective decree and certificate; hearing adjourned, costs shared.
Civil procedure — defective decree (date variance) — Order XX Rule 7 CPC; defective certificate of delay — vitiation and rectification; Rule 96(7) Court of Appeal Rules — leave to lodge supplementary record; Appellate Jurisdiction Act (ss.3A,3B) — overriding objective; costs — parties to bear own costs where defect attributable to court registry.
2 July 2021
Notes to a VAT schedule cannot expand taxing provisions; ambiguity resolved for the respondent and the appeal dismissed.
VAT — Interpretation of s.10(1) and Second Schedule item 8(1),(2) — Effect of notes/explanations as internal aids — Strict construction of taxing statutes — Ambiguity resolved in favour of taxpayer — Validity of additional VAT demand on sale of land with buildings.
2 July 2021
Victim’s credible testimony and medical corroboration upheld rape conviction; date variance curable under section 234(3) CPA.
Criminal law – Rape – proof requires penetration and identity; victim’s testimony can suffice and may be corroborated by medical and witness evidence; hearsay distinguished from direct/corroborative evidence; variance in dates curable under section 234(3) Criminal Procedure Act; appellate review of defence consideration.
2 July 2021
Claims for salary arrears against a specified public corporation required court leave because they were debts provable in bankruptcy.
Bankruptcy Act s.9(1) — specified public corporations — necessity of court leave to sue; Bankruptcy Act s.35 — debts provable in bankruptcy include compensation for work and liabilities arising from obligations incurred before receiving order; creditor status — claims capable of computation are creditors; procedural consequence — suit struck out (not dismissed) where leave absent.
1 July 2021
Review alleging manifest error, defective charge and fraud/perjury dismissed; review cannot substitute for appeal.
Criminal procedure – Review of Court of Appeal judgment – Rule 66(1) grounds: manifest error on the face of the record; nullity; fraud or perjury; jurisdiction – Review not a substitute for appeal – territorial jurisdiction of trial courts within a region.
1 July 2021
Splitting the particulars of armed robbery into a separate grievous-harm count rendered the charge defective and the trial unfair.
Criminal law – Charge sheet and particulars – Improper splitting of armed robbery into armed robbery and causing grievous harm – Particulars must give clear information to accused – Section 132 Criminal Procedure Act – Section 388 CPA cannot cure fundamental defect – Revision jurisdiction under s.4(2) Appellate Jurisdiction Act – Miscarriage of justice – Quash conviction, set aside sentences.
1 July 2021
June 2021
An erroneous Registrar’s certificate of delay cannot extend the appeal period; appeal struck out as time-barred.
Civil procedure – Appeals – Rule 90(1) Court of Appeal Rules; certificate of delay; when time for instituting appeal accrues; registrar’s notification vs collection date; evidential burden to prove receipt; defective certificate renders time exclusion ineffective.
30 June 2021
High Court lacked jurisdiction to extend time for appeal from a subordinate court with extended jurisdiction; appeal struck out.
Criminal appeal – jurisdiction – extension of time to file notice of appeal – Appellate Jurisdiction Act s.11(1) – subordinate court exercising extended jurisdiction has exclusive competence to extend time – High Court lacked jurisdiction – defective notice of appeal – Court of Appeal’s revisionary powers under s.4(2) AJA – appeal struck out.
29 June 2021
Court upheld murder conviction, expunged unlisted exhibits, and dismissed the appeal.
Criminal law – murder – proof beyond reasonable doubt; committal procedure – section 246(2) CPA – exhibits read at committal; notice to call additional witness – section 289 CPA; late amendment of information – minor amendment; accused’s rights to be addressed – section 293 CPA; alibi – section 194 CPA and judicial discretion; identification by recognition versus identification parade.
28 June 2021
Inadequate summing up and unreliable cautioned statement led the court to quash conviction and order appellant's release.
Criminal procedure – trials with assessors – duty to direct assessors on essential points including ingredients of offence, common intention, circumstantial evidence, alibi and cautioned/confessional evidence; inadequate summing up nullifies proceedings. Evidence – cautioned statement – voluntariness and proper timing; prosecution’s duty to prove absence of torture; repudiated/confessed statements must be corroborated and proven voluntary before admission. Revision – invocation of revisional powers (s.4(2) AJA) to quash conviction where proceedings are a nullity and remaining evidence is insufficient; retrial refused where prosecution’s case is deficient.
25 June 2021
Appeal allowed: trial court erred by relying on unadmitted annexures; plaintiff failed to prove breach of contract.
Commercial law – Marketing Licence Agreement – admissibility of documents – annexures to pleadings and witness statements not evidence unless tendered and admitted – burden of proof to tender contract and prove breach – Rule 67 (Commercial Court Rules) delay in judgment does not vitiate judgment absent miscarriage of justice.
25 June 2021
Inadequate summing‑up to assessors on circumstantial evidence and recent possession rendered the trial a nullity; retrial refused due to weak prosecution.
Assessors—insufficient summing‑up on circumstantial evidence and recent possession; trial rendered a nullity; Criminal Procedure Act ss.265, 298; committal procedure—s.289(1) non‑compliance and expunction of evidence; failure to call material witnesses—adverse inference; retrial principles—Fatehali Manji; appellate power under AJA s.4(2) to quash and set aside.
22 June 2021
Retracted cautioned confessions admissible if judicially warned and corroborated; JP-recorded confession vitiated for non‑compliance.
Criminal law – Murder – Reliance on retracted cautioned statements – Trial judge must warn herself of dangers and be satisfied of truth; extra-judicial statements by Justices of the Peace must comply with Chief Justice's Instructions; corroboration by independent evidence and autopsy may validate retracted confessions.
21 June 2021
Conviction quashed because night-time visual identification and inconsistent prosecution evidence made the conviction unsafe.
Criminal law – Visual identification – Waziri Amani guidelines – need for sufficient light, proximity, duration and particular features to exclude mistaken identity. Evidence – credibility and consistency of prosecution witnesses; hearsay and contradictions undermining identification. Criminal appeal – interference with concurrent findings where there is misapprehension of evidence or miscarriage of justice. Criminal Procedure Act (s.210(3)) – reading evidence to witnesses requirement and record compliance.
17 June 2021
Material variance between charge particulars and evidence (tricycle vs motorcycle) warranted quashing the conviction.
Criminal law – Variance between particulars in charge sheet and evidence (motor tricycle v. motorcycle) – Amendment under s.234 Criminal Procedure Act required – Failure to amend fatal to prosecution – Conviction quashed.
17 June 2021
Change and abandonment of assessors during trial rendered the proceedings and judgment null, and the matter was remitted for rehearing.
Civil procedure – land matters – assessor‑assisted trials – mandatory requirement to sit with same assessors throughout trial unless statutory exceptions apply. Change or abandonment of assessors mid‑trial – procedural irregularity rendering proceedings and judgment a nullity. Remedy – nullification and remittal for rehearing; parties bear own costs.
16 June 2021
Court held challenged grounds are points of law; defective certificate may be rectified, hearing adjourned.
Labour law – appeal to Court of Appeal from Labour Court – section 57 LIA: appeals on points of law only. Jurisdiction – whether CMA referral form was duly filed and served under section 86 ELRA. Employment law – whether employer proved valid reason for termination under section 37 ELRA. Procedural – completeness of record under rule 96(1) and validity of certificate of delay under rule 90(1); requirement of three clear days' notice under rule 107(1).
15 June 2021
Bias in a case-to-answer ruling and failure to explain section 231(1) rights vitiated the trial; conviction quashed and release ordered.
Criminal procedure – Ruling on a case to answer – Judicial bias where court states prosecution proved case before defence heard; non-compliance with section 231(1) CPA – rights of an accused to be informed and to call witnesses; visual identification – reliability and investigative irregularities; revisional powers under section 4(2) AJA; retrial and interests of justice.
15 June 2021
Amendment removing dismissal for missing written submissions was not applied retrospectively; single Justice properly exercised discretion.
Civil procedure — Reference under Rule 62 — scope of full Court review of single-judge decisions; discretionary relief. Court of Appeal Rules, 2009, Rule 106 — requirement to file written submissions; Rule 106(9) (pre-amendment) sanction of dismissal for non-compliance; GN No. 362 of 2017 amendment removing dismissal sanction. Retrospectivity — procedural amendments generally retrospective unless injustice results; application of amended rule refused where decision made before amendment and matter not pending. Waiver of filings — inadvertence and non-complexity do not necessarily amount to exceptional circumstances to excuse non-compliance.
14 June 2021
Risk of eviction and a firm affidavit undertaking justified a conditional stay of execution pending appeal.
Civil procedure — Stay of execution (Court of Appeal Rules 11(3)–(7), 48(1)) — requirements of substantial loss and security; security for non-monetary decrees — bond to maintain status quo; affidavit undertaking may constitute sufficient security.
11 June 2021
The Court dismissed the appellant's appeal, upholding CMA awards for unfair termination and associated statutory payments.
Labour law – unfair termination – statutory entitlements on termination including payment for remaining contract period and subsistence allowance; Employment and Labour Relations Act – section 43 (repatriation and subsistence allowance) – repatriation not conditional on employee confirming date of departure; Evidence – admissibility of documents – copies excluded at CMA cannot form basis of appeal; Appellate procedure – appeals from Labour Court limited to points of law (s.57 Cap.300); Civil procedure – parties bound by grounds of appeal and written submissions (Rules 93 and 106 Court of Appeal Rules).
11 June 2021
The Court dismissed the appellants' appeal, refusing to consider new grounds and finding the respondent’s notice of appeal valid.
Criminal procedure – appellate jurisdiction – appellate court will not entertain grounds not raised in prior appeal; afterthoughts excluded. Criminal procedure – notice of intention to appeal – omission of statutory citation not necessarily fatal where requirements otherwise met. Evidence – variance in dates between charge and witness testimony – immaterial if not prejudicial to accused. Remedies – compensation for property loss by arson to be pursued in civil suit.
11 June 2021
Convictions quashed where key exhibits were unprocedurally admitted and prosecution failed to prove the case beyond reasonable doubt.
Criminal law – Evidence – Improper admission of exhibits: cautioned statement read out before admission; exhibits tendered by prosecutor instead of a witness – identification of property (mobile phone) requiring particularisation (e.g., IMEI) – second appeal interference where misapprehension or procedural irregularity causes miscarriage of justice.
11 June 2021
Minor's unsworn testimony expunged, but medical findings plus witness confessions upheld the rape conviction.
Evidence Act s.127 (tender age witnesses) – promise to tell the truth required; failure to ensure understanding renders testimony valueless. Oaths and Statutory Declarations – form of recording "has sworn/has affirmed" curable and not fatal. Criminal Procedure – failure to read admitted exhibits (PF3, birth certificate) prejudicial and grounds for expungement. Confession – oral confession before reliable witnesses may suffice to support conviction; medical evidence can corroborate penetration. Preliminary hearing – must record disputed and undisputed facts properly though defects do not always require retrial.
11 June 2021
A limitation objection is a pure point of law; failure to plead statutory exemption renders a compensation suit time-barred.
Limitation of actions – Land/compensation claims – applicability of item 1, First Schedule to the Law of Limitation Act (12 months) ; Civil procedure – preliminary objection – point of law vs mixed question of fact; Pleading – Order VII r.6 CPC requires specific pleadings for exemption from limitation; Negotiations for settlement do not toll or exclude limitation period under the Law of Limitation Act.
10 June 2021
Review dismissed: disagreement with appellate conclusion and re‑evaluation of evidence are not grounds for review.
Criminal procedure — Review under Rule 66(1)(a) & (b) — manifest error on face of record; denial of opportunity to be heard — Review not to re‑evaluate evidence or serve as appeal. Criminal law — self‑defence — appellate scrutiny of defence and requirement for material evidence under s.18A Penal Code. Finality of litigation — review exceptional and limited to patent errors causing miscarriage of justice.
10 June 2021