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.

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26 Kivukoni Road Building P.O. Box 9004, Dar Es Salaam, Tanzania.
69 judgments

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69 judgments
Citation
Judgment date
October 2022
Successor chairman must record reasons for takeover and assessors must give opinions in parties' presence; failure voids proceedings.
Civil procedure — succession of judicial officer — Order XVIII r.10(1) CPC — mandatory requirement for successor to state reasons when taking over a partly heard case; failure renders proceedings void. Land tribunal procedure — Regulation 19(2) DLT Regulations — assessors must give written opinions to chairman in presence of parties and those opinions must be read before judgment. Remedy — where successor failed to assign reasons and assessors' opinions not recorded, proceedings and appeals are nullified and a fresh trial ordered.
31 October 2022
Failure to inform and adequately sum up to assessors on vital legal points renders the trial null, requiring retrial.
Criminal procedure – Assessors – duty to explain role and duties at trial – summing-up – mandatory duty to direct assessors on vital points of law (circumstantial evidence, cautioned statement, alibi, last-seen doctrine) – omission renders trial a nullity – retrial ordered.
31 October 2022
Inadequate summing up to assessors on circumstantial evidence and confession renders the trial a nullity; retrial ordered.
Criminal procedure – summing up to assessors – section 298(1) CPA – mandatory duty to explain substance of evidence and direct on salient legal points; Evidence – circumstantial evidence and presumption of last person seen with deceased – requirement to direct assessors; Evidence – confessional/cautioned statement – need to direct on reliability; Procedural irregularity – inadequate summing up renders trial without assessors and a nullity; Remedy – conviction quashed, sentence set aside, retrial ordered.
31 October 2022
Failure to inform and properly address assessors vitiated the trial; conviction quashed and retrial ordered.
Assessors' participation – must be informed of roles before trial; summing up to assessors – judge must summarize evidence and explain vital points of law (circumstantial evidence, corroboration, retracted confession, common intention, last-seen doctrine); introduction of extraneous matters in summing up vitiates trial; where trial vitiated by such defects, retrial may be ordered.
31 October 2022
The applicant's unequivocal guilty plea to child rape precludes appeal on conviction; mandatory life sentence was lawful.
Criminal law – guilty plea – effect of plea under s.360(1) CPA – limited exceptions per Laurence Mpinga – plea must be unequivocal, not ambiguous or mistaken. Evidence – medical examination report (PF3) as proof of penetration in child rape cases. Sentencing – subordinate court jurisdiction to impose mandatory minimum life sentence for rape of a child under ten years (s.170(1)(a) and Minimum Sentences framework).
31 October 2022
Material variance between charged date and prosecution evidence undermined proof beyond reasonable doubt; conviction quashed.
Criminal law – unnatural offence – variance between charge particulars (date) and prosecution evidence – duty of prosecution to prove particulars – requirement to amend charge under section 234(1) Criminal Procedure Act – failure to address variance amounts to fatal defect.
28 October 2022
Credible eyewitness testimony can sustain a child sexual‑abuse conviction despite hearsay and absence of medical or victim testimony.
Criminal law – child sexual offence – sufficiency of eyewitness evidence; hearsay; absence of medical expert or child victim testimony; second appeal standard — concurrent findings disturbed only for misdirection/non-direction; Evidence Act s.143; convictions may stand on credible oral eyewitness accounts.
27 October 2022
Court expunged improperly admitted PF3 but upheld rape conviction, finding core evidence proved all elements beyond reasonable doubt.
Criminal law – Rape – elements required: penetration, victim’s age, identity of assailant; Charge‑sheet defects – omission of punishment subsection curable under s.388(1) CPA; Variance between charge and evidence – time/age discrepancies immaterial if core evidence consistent; Documentary evidence – PF3 must be properly admitted (read aloud) or be expunged; Appeal procedure – appellate court duty to re‑evaluate defence evidence when first appellate court fails.
27 October 2022
Procedural defects were curable; convictions upheld and EOCCA sentence increased to the statutory minimum of 20 years.
Economic offences – jurisdiction – DPP certificate – erroneous reference to EOCCA subsections; Criminal Procedure Act – accused’s right to be addressed under s.231(1) – curable omissions under s.388(1); Oaths Act/Cap 34 – affirmation where no religion; Evidence – failure to read exhibit over in court – expunction; Sentencing – EOCCA s.60(2) minimum sentence for economic offences – enhancement to 20 years.
27 October 2022
Victim’s credible uncorroborated testimony upheld under Evidence Act; curable procedural and naming errors did not vitiate conviction.
Criminal law – Rape – conviction may rest on uncorroborated testimony of sexual‑offence victim where court records reasons and finds the witness credible (Evidence Act s.127(6)). Criminal procedure – Record authentication – omission to append signature after each witness not necessarily fatal if proceedings are signed at end of day. Pleadings – Variance/misspelling in name in charge – curable defect where no prejudice to accused (charge not misleading). Evidence – Improperly admitted medical report expunged but conviction may stand on credible victim’s testimony. Appellate review – evaluation of credibility ordinarily left to trial court; appellate interference limited absent demonstrable misdirection.
27 October 2022
A prior court's final judgment bars re-litigation of the same land dispute; church settlements cannot override it.
Civil procedure – res judicata – applicability where prior suit finally decided by a competent court under section 9 CPC. Res judicata – five conditions: same matter, same parties/privies, same title, competent court, final decision. Non-judicial settlements – church-mediated settlements cannot overturn or supersede a court's final judgment. Administrator of estate – barred from re-litigating property already finally determined by competent court.
27 October 2022
Conviction for unnatural offence upheld despite a mis-cited provision; competent child’s unsworn testimony sufficed.
Criminal law – Unnatural offence (s.154 Penal Code) – Wrong citation of paragraph (b) relating to animals held inconsequential; no requirement to cite punishment provision in charge sheet. Criminal procedure – Particulars of offence – Stating place as 'Esso Area' sufficient under s.135(1) CPA where no prejudice shown. Evidence – Child witness – Voir dire and unsworn testimony admissible; credibility and demeanour for trial court to assess. Evidence – Absence of medical/PF3 evidence not fatal; penetration need not depend solely on medical proof. Appeal – Appellate re-evaluation – Conviction and sentence affirmed where all ingredients proven beyond reasonable doubt.
26 October 2022
Second appeal dismissing challenge to drug trafficking conviction: EOCCA consent not required, chain of custody and cautioned statement lawful.
Criminal law – Drugs – Trafficking in cannabis – admissibility and chain of custody of seized drugs – oral and documentary proof of continuity of custody. Evidence – cautioned statement – compliance with section 50 Criminal Procedure Act (four-hour rule). Jurisdiction – EOCCA – DPP consent not required where offence is not an economic offence under the First Schedule. Appellate procedure – second appeal cannot entertain new factual issues not raised before first appellate court.
24 October 2022
Applicant’s absence did not exceed five working days; termination was unjustified and Court’s earlier decision reviewed and set aside.
Court of Appeal — Review under Rule 66(1)(a) — Limits of review (manifest error vs re-assessment of evidence); Evidence Act s.59(1)(g) — judicial notice of public holidays; Employment law — abscondment and Code of Good Practice rule 9(1) — termination requires absence over five working days; Procedural fairness — allegation of denial of disciplinary hearing considered a new ground.
24 October 2022
Failure to show good cause for non-appearance justifies dismissal of application to set aside ex parte judgment.
Civil procedure – setting aside ex parte judgment – rule 43(2) High Court (Commercial Division) Procedure Rules – applicant must show good/sufficient cause; party’s duty to follow up counsel’s conduct; substantive challenges to underlying suit irrelevant to setting aside application.
24 October 2022
Failure by the first appellate court to decide all grounds renders its judgment null and warrants remittance for rehearing.
Criminal procedure – appeal – failure of first appellate court to consider grounds of appeal – fatal irregularity; judgment nullity. Evidence – visual identification and cautioned/confessional statements – issues as grounds of appeal requiring proper appraisal. Appellate practice – when Court of Appeal may step into shoes of first appellate court versus when to remit for rehearing.
24 October 2022
A PSA does not confer stamp‑duty exemption absent a Ministerial Gazette notice; appellant failed to prove exemption, appeal dismissed.
Stamp Duty – instruments executed outside Mainland Tanzania – s.5(1)(b) Stamp Duty Act – chargeable if relating to Mainland property; Exemption – requires Ministerial notice in Gazette – s.16(1) Stamp Duty Act; Burden of proof – appellant to prove exemption – s.18(2)(b) TRAA; Stamping of foreign instruments – s.26 Stamp Duty Act; Procedure – objection determination and Notice of Confirmation of Assessment; production/registration of tax agreements (s.143 ITA).
24 October 2022
Informal alteration of a charge sheet is inadequate; failure to formally amend a defective charge renders conviction a nullity.
Criminal procedure — Charge sheet materially inconsistent with evidence — Amendment under section 234(1) CPA required — Informal crossing out insufficient — Accused must be re‑read the amended charge. Criminal procedure — Defective charge causing prejudice — Incurable defect — Section 388 CPA inapplicable. Appellate jurisdiction — Proceedings nullified where trial was unfair — Conviction and sentence quashed; release ordered.
21 October 2022
Oral testimony, not documentary exhibits, sufficed to uphold corruption convictions; witnesses were not accomplices and did not require further corroboration.
Criminal law – Corruption – Soliciting and receiving bribe; Evidence – accomplice vs witness with interest; corroboration of accomplice evidence – section 142 Evidence Act; admission and expungement of documentary exhibits; sufficiency of oral evidence to uphold conviction.
21 October 2022
Variance between charge date and evidence, plus failure to call material witness, led to quashing of conviction.
Criminal law — Particulars of offence — Prosecution obliged to prove date/time/place where specified in charge; material variance between charge and evidence fatal; failure to call material witness permits adverse inference; appellate interference with concurrent findings justified where prosecution fails to prove essential particulars.
21 October 2022
Child’s testimony and medical report were credible; earlier-recorded evidence lost weight after lawful resummoning, and life sentences ordered concurrent.
Criminal law — Evidence Act s127(2),(6) — Child of tender years — Requirements for promise to tell the truth; Medical evidence — PF3 admissibility — competence of examining practitioner; Criminal Procedure Act s214 — resummoning witnesses and evidential effect of earlier-recorded testimony; Sentence — multiple life terms and concurrency; Appellate revisional powers.
21 October 2022
Failure to serve the notice of motion within 14 days under Rule 55(1) renders the application incompetent.
Civil procedure – Service of notice of motion – Rule 55(1) TCA Rules (2009) – Mandatory requirement to serve notice and supporting documents within 14 days – Failure to prove service renders application incompetent – Overriding objective cannot cure non‑compliance with mandatory rules – Enerico Kakala; Sadallah precedents.
20 October 2022
Motorcycle rider acquitted for lack of common intention; principal's possession conviction and mandatory sentence upheld.
Wildlife Conservation Act – unlawful possession and dealing in government trophies; chain of custody and exhibit register; validity and sufficiency of Trophy Valuation Certificate; search and seizure (WCA s.106, CPA s.38) and validity of seizure document; common intention doctrine; delegation of prosecutorial consent (G.N. No. 284 of 2014); mandatory minimum sentencing under WCA s.86(2)(b).
19 October 2022
Whether management/service fees to a foreign resident fall within the DTA and exempt Tanzanian withholding tax.
Double Taxation Agreement – Article IV(1) – interpretation to include management/service fees as "industrial and commercial profits"; withholding tax – source and residence tests; Income Tax Act (sections 6, 69, 83) – obligation to withhold on services rendered in Tanzania; permanent establishment – attribution and relief; treaty interpretation principles vs OECD commentary.
19 October 2022
Committal notice failure and inadequate guidance to assessors rendered trial evidence inadmissible and convictions unsustainable.
Criminal procedure – committal proceedings and notice – section 289(1) CPA; inadmissibility and expunction of witnesses/exhibits not listed at committal.\nCriminal procedure – role of assessors – judge’s duty to adequately sum up on vital legal points (visual identification, circumstantial evidence, recent possession, confessional statements) – misdirection vitiates proceedings.\nEvidence – visual identification and identification parade reliability.\nRemedy – quashing convictions and sentences; discretionary refusal to order retrial.
19 October 2022
Guarantor’s unilateral termination ineffective; guarantor liable only for 80% of principal; unaccounted seized assets must be deducted.
Banking law – term loan – secured loan with cash deposit, equipment registration, personal guarantees and hypothecation – guarantor’s termination of guarantee – contractual termination procedure – guarantor liable for 80% of outstanding principal only – guarantor not liable for interest – seizure and public auction of secured chattels – directors’ personal guarantees and hypothecation pierce corporate veil – failure to account for seized but unsold assets entitles borrower to deduction.
19 October 2022
Second-bite leave in land appeals is competent after s.47 amendment; arguable illegality granted leave to appeal.
Appeal – Land law – Second-bite leave under Rule 45(b) – Competence after 2018 amendment of s.47 Cap.216 – High Court and Court of Appeal concurrent jurisdiction; Judicial procedure – Leave to appeal – Prima facie illegality – Failure to record assessors’ opinions; unexplained change of assessors; jurisdictional challenge; alleged double allocation; Relief – Leave to appeal granted; no order as to costs.
19 October 2022
Assessors' briefing omission cured; despite some errors expunged, evidence sufficed to uphold murder conviction and death sentence.
Criminal appeal — assessors' briefing omission cured where assessors actively participated; admissibility — error in court referring to non‑tendered cautioned statement must be expunged; discrepancies in delayed witness testimony may be minor; last‑seen doctrine and eyewitness/autopsy evidence can sustain murder conviction; rejection of defence does not imply non‑consideration.
18 October 2022
Review dismissed: applicant failed to show denial of hearing or manifest error; review cannot substitute for re‑hearing of appeal.
Appellate procedure — review under Rule 66(1) — review limited to manifest errors on face of record or denial of hearing; criminal evidence — admissibility and chain of custody of exhibits; Evidence Act s.34B(2) — admission of unavailable witness statements; review not to serve as rehearing of appeal.
18 October 2022
A one-day delay in filing a revision application is jurisdictional and not excused by the Overriding Objective.
Civil procedure – Revision application – Time limit – Even a one-day delay must be accounted for – Time bar affects jurisdiction – Overriding Objective cannot cure jurisdictional non-compliance with filing time limits.
18 October 2022
Trial by a magistrate lacking a High Court transfer order is a jurisdictional nullity and cannot be cured by overriding objective.
Criminal procedure – Transfer under s.256A(1) CPA – transfer must be directed to a specific resident magistrate with extended jurisdiction. Jurisdiction – Proceedings, trial and judgment by magistrate lacking a transfer order are a nullity. Overriding objective / s.388 CPA – cannot cure jurisdictional defects. Appellate revision – s.4(2) AJA used to nullify proceedings, quash conviction and remit record to High Court.
18 October 2022
An application for extension to appeal a High Court refusal of leave is misconceived and is struck out.
Appellate procedure – extension of time to apply for leave to appeal – concurrent jurisdiction of High Court and Court of Appeal (s.11 AJA; Rules 45(b), 45A(1)(b), 47) – 'second bite' doctrine – refusal of leave by High Court non-appealable – competence of application.
13 October 2022
Alleged illegality in the High Court’s decision constitutes good cause to extend time to file an appeal.
Extension of time – Rule 10 – good cause – requirement to account for delay – illegality of lower court decision as sufficient ground – right to be heard – leave to appeal.
13 October 2022
Conviction for rape of a two‑year‑old affirmed; procedural omissions curable and non‑prejudicial.
Criminal law – Rape of child under ten – Charge sheet omissions – sentencing provision not mandatory on charge sheet; curable under s.388 CPA – Evidence: medical and eyewitness proof of penetration and identity – s.211(1) (interpretation) and s.312(2) (judgment specification) non‑compliance curable if not prejudicial.
13 October 2022
Trial conducted outside the territorial court specified in the transfer order lacked jurisdiction and was nullified.
Criminal procedure – Transfer under section 256A(1) CPA – Territorial jurisdiction – Resident Magistrate with extended jurisdiction must sit at court and region specified by transfer order – Trial held outside designated territorial court is nullity – Proceedings quashed and remitted to High Court.
13 October 2022
Applicant failed to account for each day's delay; alleged illegality alone did not justify extension to seek a stay.
Civil procedure — Rule 10 extension of time — requirement to account for each day of delay; illegality as ground for extension — only where extension enables remedy; stay of execution applications.
13 October 2022
An unequivocal guilty plea admitting all elements bars appeal; exhibits tendered after plea need not be read aloud.
Criminal law – guilty plea – requirements for an unequivocal plea – charge and facts to be stated and admitted; Criminal law – appeals from guilty pleas – grounds permitting appeal (misapprehension, ambiguity, no offence disclosed); Evidence – tendering exhibits after guilty plea – permissible and contents need not be read aloud; Procedure – age ascertainment – where age is in charge sheet and not disputed, no further proof required.
13 October 2022
Court dismissed appeal, finding identity and statutory rape proved despite PF3 expunged and minor inconsistencies.
Criminal law – Rape/statutory rape – Proof of age of victim; Identification evidence – visual ID under poor lighting; E vidence – variance in time immaterial; PF3 (medical report) not read out and expunged; Absence of investigating officer's testimony not fatal where credibility of other witnesses suffices.
13 October 2022
Conviction for obtaining money by false pretences upheld; witness credibility and compensatory refund affirmed.
Criminal law – Obtaining money by false pretences: elements—false representation, obtaining money, intent to defraud; Evidence – credibility of witnesses and appellate restraint on reassessing demeanour findings; Evidence of relatives – admissible and may be relied upon if credible; Documentary exhibits – may be tendered by a party who possessed or dealt with them; Procedural – failure to call a witness (advocate) not fatal where other competent evidence identifies and connects exhibits.
12 October 2022
Delay and counsel negligence do not justify extension; alleged illegality must be apparent on the record.
Extension of time – Rule 10 Court of Appeal Rules – requirement to account for each day of delay – advocate’s negligence not a sufficient cause – illegality as ground for enlargement of time must be apparent on face of record – alleged improper interest awards not shown to be manifestly illegal.
12 October 2022
Conviction quashed: illegal night search without warrant and broken chain of custody rendered evidence unreliable.
Criminal law – Drug trafficking – Proof beyond reasonable doubt – admissibility and reliability of seized narcotics. Search and seizure – Requirement of search warrant and compliance with CPA (time and court leave) – illegally obtained evidence. Evidence – Chain of custody – need for continuous, documented custody and oral account to exclude tampering. Criminal procedure – Defective charge – curability under section 388(1) CPA where particulars inform accused of offence.
11 October 2022
Review refused: applicant’s dissatisfaction and reliance on a power of attorney did not constitute manifest error or denial of hearing.
Court of Appeal — Review jurisdiction — Rule 66(1) AJA — Error apparent on face of record — Limited grounds for review — Review not an appeal in disguise; Locus standi — Capacity to sue — Power of attorney does not cure lack of legal capacity.
7 October 2022
Court found appellant's imported maize seeds failed germination; damages reduced to amounts strictly proved and dealer's award vacated.
Seed certification and quality – TOSCI germination testing – weight and credibility of expert certification versus supplier certificates. Evidence – admissions under Order XII rule 1 CPC binding between parties. Estoppel – promissory/conduct-based estoppel where supplier dealt with a dealer and cannot later deny dealer status. Damages – special damages must be specifically pleaded and strictly proved; courts will vary awards to amounts strictly evidenced.
7 October 2022
Amendment limiting import-duty exemptions did not retrospectively remove benefits protected by pre-existing investment certificates; appeal dismissed.
Investment law – certificate of incentive as government-investor agreement; protection of benefits under section 19(2) TIA; non‑retrospectivity of Finance Act 2013 amendments; extensions vs new certificates; interaction between EACCMA and domestic customs law on exemptions.
7 October 2022
Child victim’s properly received credible evidence and medical PF3 established rape; appeal dismissed.
Evidence Act s.127 (child witness) – procedure for receiving evidence of a child of tender age; inquiry into understanding of oath. Sexual offences – best evidence usually from the victim; corroboration by medical PF3. Delay in reporting – immaturity, fear or shame may justify delay and does not necessarily undermine credibility. Appellate review – deference to trial court’s and first appellate court’s concurrent findings on credibility absent cogent reasons to overturn.
7 October 2022
Termination was substantively and procedurally unfair; compensation adjusted and contingent contractual benefits disallowed.
Employment law - unfair termination - substantive and procedural fairness; burden of proof for alleged misappropriation; requirement to produce/serve investigative/audit reports; section 40 ELRA remedies - compensation plus contractual entitlements; distinction between vested and contingent contractual benefits; computation of repatriation and subsistence allowance.
7 October 2022
Applicant's claims about alibi/credibility and denial of hearing were appellate issues, not grounds for review; application dismissed.
Criminal procedure — Review under Rule 66 — Scope limited to manifest error apparent on face of record, denial of hearing, nullity or lack of jurisdiction; issues of alibi, witness credibility, or adequacy of lower court judgments are appellate matters, not review grounds.
7 October 2022
Alleged illegality (including lack of jurisdiction) can constitute sufficient cause to enlarge time to file a notice of appeal.
Extension of time — sufficient cause — illegality as ground for enlargement of time; challenge to trial court's pecuniary jurisdiction; default judgment; appellate supervisory jurisdiction; exercise of judicial discretion.
7 October 2022
Court quashed dismissal and substituted striking out where eviction application was incompetent and sale predated stay.
Civil Procedure – Revision – timeliness under Rule 65(4) – revision of High Court Ruling of 10/2/2021. Execution and stay – sale by public auction pre-dating stay of execution – non-disclosure to court. Civil Procedure – incompetent application – striking out versus dismissal – dismissal inappropriate where matter not determined on merits.
7 October 2022
Applicant failed to show sufficient cause under Rule 63(3) to justify re-hearing of an application heard in its absence.
Civil procedure – re-hearing/restoration under Rule 63(3) – requirement to show "sufficient cause" to re-hear an application heard and allowed in a party's absence. Evidence – need for corroboration (affidavits from court staff) to substantiate claims of misdirection or attendance at wrong courtroom. Medical evidence – medical chit must sufficiently demonstrate inability to attend. Procedural grounds – importance of intended appeal does not, by itself, constitute sufficient cause for re-hearing.
6 October 2022