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.
83 judgments

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83 judgments
Citation
Judgment date
May 2022
Appellant's registered road signs reproduced and sold in respondent's training book without consent — copyright infringement; Tshs 50,000,000 awarded.
Copyright — registration and protection of literary/artistic works; reproduction, distribution and sale as infringement of economic and moral rights; evidentiary requirement to list and tender relied-on public documents; fair-use/teaching exceptions considered but not established; award of general damages where specific loss not proved.
30 May 2022
Applicant failed to show good cause or provide acceptable security for stay of execution pending appeal.
Civil procedure — Stay of execution under rule 11(3) — Conditions in rule 11(5)(a) and (b) must be satisfied cumulatively; disputed property cannot be offered as security; third-party titles without ownership/consent are insufficient security; failure to prove substantial or irreparable loss — application dismissed.
30 May 2022
An appeal to the Tax Board is limited to objection decisions; a demand for tax that is not an objection made the Board’s proceedings a nullity and the appeal incompetent.
Tax law – Appealability – TRAA s.16(1) limits appeals to the Board to objection decisions under the TAA – non-objection demands are not appealable to the Board. Tax Administration – Objection procedure – section 51 TAA and regulations prescribe form and prerequisites for valid objections. Procedural jurisdiction – Proceedings founded on an incompetent appeal are a nullity and can be quashed under revisional jurisdiction. Execution – Whether a demand for tax arising from a Tribunal decree requires an application for execution was considered in context but jurisdictional rules governed outcome.
30 May 2022
Appellant liable for unpaid purchase price; respondent awarded interest, with post‑filing rate reduced to agreed 8.76% p.a.
Sale of goods – formation of contract by proforma invoices and purchase orders – proof of unpaid balance – burden and standard of proof in civil claims – mercantile practice and entitlement to interest on commercial debts – assessment of witness credibility and documentary evidence (failure to produce account records).
30 May 2022
Second‑bite application for extension of time dismissed for failing to account for delay and show diligence.
Court of Appeal — extension of time — rule 45A(1)(b) as gateway; substantive discretion under rule 10; requirements for "good cause" — explanation for delay; accounting for each day; diligence; illegality; failure to account for delay warrants refusal.
25 May 2022
A stay application is incompetent where the mandatory notice of appeal has been struck out; application struck out with no costs.
Civil procedure – Stay of execution – Rule 11(3) (stay on good cause) and rule 11(7) (mandatory documents) – A copy of the notice of appeal is a mandatory prerequisite to a stay application. Competence – Application overtaken by events where the notice of appeal has been struck out. Rule 4(2) – Court declined to invoke rule 4(2) to adjourn or cure absence of mandatory documents; correct procedure is a specific stay pending review application.
25 May 2022
Stay of execution granted pending appeal subject to bank guarantee of TZS 1,204,042,277.70.
Stay of execution – Rule 11(5) Tanzania Court of Appeal Rules – requirement of substantial loss and security; firm undertaking as sufficient; bank guarantee as acceptable form of security; stay granted pending appeal.
25 May 2022
Revocation of a right of occupancy is unlawful where respondents fail to prove an operative disposition amounting to good cause.
Land law – Right of occupancy – Revocation under section 10(1) of the (repealed) Land Ordinance – requires proof of good cause. Disposition of right of occupancy – Regulation 3 of the Land Regulations – consent of Commissioner for Lands essential; disposition without consent inoperative. Burden of proof – on party alleging disposition/breach; failure to prove renders revocation unlawful. Sub-division and reallocation following unlawful revocation are invalid.
25 May 2022
An invalid certificate of delay unsupported by the record renders the appeal time-barred and liable to be struck out.
Civil procedure — Appeal time limits — Rule 90(1) Court of Appeal Rules — Certificate of delay must be free from error and dates borne out of the record; period of exclusion runs to date Registrar wrote notification letter. Supplementary record — leave to file may be granted once; further supplementation refused where futile. Cross-appeal — survives striking out of main appeal. Change of corporate name — may be regularized on record with BRELA certificate.
24 May 2022
Applicant granted extension to apply for stay of execution based on alleged illegality in High Court proceedings.
Civil Procedure — Extension of time under Rule 10 — Sufficient cause requires accounting for each day of delay and diligence; illegality in challenged decision may constitute sufficient cause; Registrar’s rejection must be in writing and substantiated; applicant must produce rejected documents or proof of communication.
24 May 2022
Appellant failed to prove good title; respondent declared lawful owner and appeal dismissed with costs.
Land law – ownership and title; burden of proof in civil claims; nemo dat quod non habet; admissibility of public documents (Evidence Act ss.83–84); requirement to plead and prove adverse possession; necessity to call or join essential witnesses; challenge to certificate of title and particulars of fraud.
24 May 2022
An erroneous certificate of delay unsupported by the record renders an appeal time-barred and incompetent.
Appeal procedure — Certificate of delay — Rule 90(1) and (2) — Certificate must state period excluded from request to date of notification — Material error unsupported by record renders certificate invalid — Time limitation and jurisdiction — Overriding objective cannot cure jurisdictional defects.
24 May 2022
A binding contract existed by conduct and documents; breach warranted liquidated damages, but the claimed 9.75% interest lacked proof and was set aside.
Commercial law – formation of contract by conduct and documents (proforma invoice and order) – breach for failure to deliver – liquidated damages enforceable when fixed by procurement/tender – interest: court rate 7% applies unless contractual evidence supports higher rate.
24 May 2022
The Court held the Land Division could probe probate irregularities and dismissed the appellant's appeal with costs.
Land law — jurisdiction of High Court (Land Division) to determine ownership where probate issues arise; Evidence Act ss.43 & 46 — relevance and impeachment of probate orders in civil proceedings; validity of competing letters of administration; onus/burden of proof in civil trials; non-joinder of deceased party.
24 May 2022
An order refusing a stay for arbitration is appealable, but the appeal was struck out as premature pending resolution of related proceedings.
• Arbitration — order refusing to stay proceedings — appealable under AJA s.5(1)(b)(v). • Appellate procedure — functus officio — requires final disposal of the matter. • Civil procedure — preliminary objection — Mukisa test for points of law. • Judicial discretion — striking out premature appeals to preserve good administration of justice.
23 May 2022
Trial court’s rectification of judgment while appeal pending was jurisdictionally incompetent and thus a nullity; both courts’ orders quashed.
Jurisdiction – subordinate court lacks jurisdiction to amend/rectify its judgment while an appeal to a superior court is pending; Rectification/Order XLII R.2 and s.96 CPC – trial court’s amendment while appeal pending is void; Nullity – proceedings and resulting orders without jurisdiction are nullities; Revision – High Court cannot validly decide revision arising from nullity; Appellate revisional powers – s.4(2) AJA invoked to nullify, quash and set aside orders.
20 May 2022
A labour applicant cannot use Court of Appeal revision to re-assess factual findings barred by section 57 LIA.
Labour law – Appeals under section 57 LIA limited to points of law – Revision not an alternative to appeal. Civil procedure – Revisional jurisdiction – scope limited to supervisory review; re-assessment of evidence only where point of law (perverse finding/no evidence) arises. Practice – Applicant cannot circumvent statutory appeal limits by invoking revision; application misconceived and struck out.
19 May 2022
Appellants failed to prove repayment; mortgage discharge was fraudulently procured, appeal dismissed with costs.
Mortgage law – discharge of mortgage – alleged fraudulent discharge; Evidence – burden and standard of proof in fraud allegations; Admissibility – opinion as to handwriting by person acquainted with signature (s.49 Evidence Act); Civil appeal – re-appraisal of evidence and handling imperfect record.
18 May 2022
Unexplained failure to take essential appeal steps justifies striking out the notice of appeal.
Appeal procedure — Rule 89(2) Court of Appeal Rules — striking out notice of appeal for failure to take essential steps; Rule 90(1) — requirement to lodge memorandum and record within sixty days and furnish security; Appellate Jurisdiction Act s.11(1) governs extension of time for appealing — section 95 CPC not applicable; unexplained delay and procrastination disentitle a party to proceed with appeal.
18 May 2022
Employer refusing reinstatement pays statutory compensation plus twelve months' wages, not arrears for absence.
Employment law – Reinstatement orders – Section 42(5) election to pay statutory compensation plus twelve months’ wages – No obligation to pay wages for period of absence – Section 42(4)(a) deduction for days absent – PAYE lawful on compensation – Subsistence/extra allowances not provided by statute.
18 May 2022
Review dismissed: alleged errors were re‑argument of interlocutory matters and not apparent on the face of the record.
Civil procedure — Review — Rule 66(1)(a) Court of Appeal Rules — requires manifest error on the face of the record; not for re‑argument. Appellate Jurisdiction — Sections 4(3) and 5(2)(d) AJA — revisionary powers of Court of Appeal limited; interlocutory High Court orders not revisable where they do not finally determine the suit. Companies Act — s.233 petitions — membership/directorship status may be contentious and not determinable by premature remarks. Remedy — review dismissed where alleged errors are not obvious patent mistakes.
18 May 2022
Failure to file a Rule 45A(1)(c) second-bite application within 14 days renders an appeal incompetent and it was struck out.
Civil procedure – extension of time – Rule 45A(1)(c) Court of Appeal Rules – requirement to apply to Court of Appeal within 14 days after High Court refusal to extend time to apply for certificate on point of law – failure to comply renders appeal incompetent.
18 May 2022
Omission to include proof of service of notice of appeal in the record is not fatal; supplementary record may be allowed.
Civil procedure – preliminary objection – service of notice of appeal – Rule 84(1), 86(1), 96(1) and 96(7) of the Court of Appeal Rules, 2009 – omission to include proof of service in record not necessarily fatal – leave to lodge supplementary record – Mukisa principle on misuse of preliminary objections.
17 May 2022
Whether the applicant’s retrenchment was procedurally fair and substantively justified; failure to prove necessity invalidated retrenchment.
Employment law – retrenchment – procedural compliance with s.38 ELRA – consultation and disclosure of information.* Employment law – substantive fairness – employer's burden to prove financial necessity and that retrenchment is last resort.* Labour procedure – admissibility of documents produced at CMA hearings – documentary evidence and exhibits.* Discrimination – allegation of racial discrimination in selection for retrenchment – burden of proof.* Remedy – compensation under s.40 ELRA – 12 months' pay as statutory minimum.
17 May 2022
Review dismissed: alleged errors required re‑evaluation of evidence and were not manifest on the face of the record.
Court of Appeal — Review jurisdiction — Error apparent on face of record must be obvious and self-evident; Review not a substitute for appeal — Re‑evaluation of evidence is appellate, not review, function; Contractual/commercial interest — award depends on express agreement and is a merits issue; General and specific damages — reduction or affirmation require appraisal of evidence, not reviewable unless manifest error.
13 May 2022
Applicant failed to establish grounds to order service of the memorandum and record of appeal; application dismissed with costs.
Court of Appeal Rules — service of memorandum and record of appeal — rule 97(1) requirement to serve respondents who complied with rule 86; rule 84 dependency for service of notice of appeal; proof of service under rule 22(6) requires affidavit or oral evidence; extension of time under rule 10 when time limits lapse; rule 97(2) cannot substitute for non‑compliance with rule 97(1).
13 May 2022
Pleaded loss of business (special damages) must be strictly proved; unproven interference led to dismissal of appeal.
Civil procedure - pleadings - plaintiff bound by pleadings; loss of business/profit pleaded as special damages requires strict proof. Evidence - burden and standard of proof - section 110 Evidence Act; balance of probabilities. Damages - distinction between general and special (specific) damages; need for particularized proof of special damages. Evidence - failure to call material witnesses and produce documentary proof permits adverse inference. Evidence - audio recordings require authentication and witness identification to be conclusive.
13 May 2022
If appellate records are irretrievable and the applicant has served most of the sentence, the conviction may be quashed.
Criminal procedure – Missing appellate records – exhaustive efforts to reconstruct – relief where reconstruction fails. Remedies – retrial vs quashing conviction – when substantial term already served. Appellate jurisdiction – exercise of section 4(2) AJA to quash conviction and set aside remaining sentence. Registry responsibilities – tracing and reconstructing lost court records; condemnation of unexplained disappearances.
13 May 2022
Review refused: applicants' complaints were appeal matters or evidential issues, not manifest errors warranting review.
Criminal law & procedure – Review jurisdiction of Court of Appeal – scope of section 4(4) AJA and Rule 66(1) – manifest error on the face of the record – review not a forum to re‑argue appellate or evidential issues – sentencing under Drugs Act v. general Penal Code provision.
13 May 2022
Trial judge's failure to sign witness records rendered proceedings null, requiring retrial for the appellant.
Criminal procedure – recording of evidence in High Court – practice of judge appending signature after each witness's evidence – authenticity of record.* Failure to sign is an incurable irregularity vitiating proceedings – retrial ordered.
13 May 2022
Court upheld murder convictions, finding single-night visual identification reliable and procedural defects non‑fatal.
Criminal law – Visual identification at night – single eyewitness evidence must be watertight (light, proximity, familiarity, duration); Committal irregularity – appellate power to nullify unlawfully recorded evidence; Contradictions – minor inconsistencies do not necessarily undermine prosecution; Evidence – prosecution’s discretion on witnesses and exhibits; Delay in arrest – requires explanation but not fatal if satisfactorily explained.
13 May 2022
High Court wrongly dismissed the appellant's timely criminal appeal without hearing; matter quashed and remitted for merits.
Criminal procedure – Time limits for appeals – Section 361 CPA – notice of appeal and petition of appeal; exclusion of time taken to obtain copies. Right to be heard – natural justice – dismissal without hearing as miscarriage of justice. Civil/criminal procedure – Incompetent/time‑barred appeals should be struck out, not dismissed. Appellate jurisdiction – Revision under section 4(2) AJA to quash High Court proceedings and remit for hearing on merits.
13 May 2022
Non‑joinder of a necessary party (the bank‑guarantee beneficiary) vitiated the trial; matter remitted for rehearing after joinder.
Civil procedure – Order 1 Rule 10(2) CPC – Non‑joinder of necessary party – Bank guarantees – Beneficiary must be joined where core dispute arises from contract between customer and beneficiary – Failure to join is fatal and renders proceedings a nullity.
13 May 2022
Alleged trial-court illegality can justify extension of time to appeal despite inordinate delay.
Civil procedure — Rule 10 (extension of time) — Good cause test and Lyamuya factors Extension of time — Effect of inordinate delay — diligence and accounting for delay Illegality in trial court’s judgment — Alleged irregularities (failure to frame issues; no final pre-trial conference; unexplained change of judge) may justify extension Precedents — Principal Secretary v. Valambia; VIP Engineering; Lyamuya Construction Remedy — Grant of extension to file appeal out of time with time limit imposed
13 May 2022
Trafficking conviction quashed due to defective chain of custody and absence of required weight particulars in analyst's report.
Criminal law – narcotic drugs – trafficking under s.15A(2)(c) DCEA – essentiality of weight; evidential chain of custody – documentation and witnesses; sampling procedure – regulation 18(1) compliance; admissibility/timing/voluntariness of cautioned statement; Government Chemist report form and required particulars (weight).
13 May 2022
EJS and text‑message evidence upheld; detention during President’s pleasure lawful for offenders under eighteen.
Evidence — Extra‑judicial statements: compliance with Chief Justice’s Guide; consent, reading over, thumbprints/signatures; failure to sign every page not fatal. Evidence — Repudiated confession: admission without timely objection bars later challenge; corroboration where necessary. Electronic evidence — Mobile phone/text messages: contextual consistency sufficient; calling service provider or cyber experts unnecessary where phone led to arrest and ownership/admission by accused. Sentencing — Child offenders: section 26(2) Penal Code (detention during President's pleasure) valid substitute for death sentence for offenders under 18; not necessarily prohibited by Law of the Child Act’s ban on imprisonment.
13 May 2022
Application for extension of time dismissed for failure to account for delay and to demonstrate alleged illegality on the record.
Civil procedure – extension of time – Rule 10 Court of Appeal Rules – requirement to account for all days of delay and show diligence (Lyamuya guidelines). Review proceedings – Rule 66(1) – applicant must indicate grounds for review; alleged illegality must appear on the face of the record to justify extension. Delay – failure to account for unexplained delay and negligence/sloppiness disentitles applicant from extension.
13 May 2022
Child’s evidence retained under s127(6) despite s127(2) omission; PF3 expunged but oral medical evidence upheld; appeal dismissed.
Evidence Act s.127(2) & (6) – child witness competence and promise to tell the truth – exceptional application of s.127(6). Criminal procedure – admissibility of documentary exhibits – requirement to read exhibits aloud to accused; expungement if not complied with. Sexual offences – proof of penetration and medical evidence (PF3) – effect of expunged exhibit on oral medical testimony. Proof of age in statutory rape – parent/guardian testimony and admissions by accused sufficient. Appellate review – failure of lower courts to consider defence can be cured by appellate assessment.
13 May 2022
Two conflicting certificates of delay render an appeal incompetent; appeal struck out as time-barred.
Appeal — certificate of delay — two conflicting certificates issued by Registrar — Registrar cannot extend filing time — Rule 90(1) TCAR — first certificate not withdrawn — appeal time-barred — struck out with costs.
13 May 2022
Child witness’s promise to tell the truth must be recorded; without that evidence prosecution failed and conviction was quashed.
Evidence — Child witness (tender age) — Section 127(2) Evidence Act — requirement to record the child’s promise to tell the truth — necessity to record the child’s words or clear engagement. Criminal law — Proof of identity and commission — where child testimony excluded, remaining evidence must independently prove guilt beyond reasonable doubt. Procedure — Cautioned statement previously expunged; appellate scrutiny of admissibility and sufficiency of evidence. Sentencing — life sentence set aside where conviction unsustainable; question of juvenile sentencing under section 131(2)(a) noted.
12 May 2022
Unsworn witness testimony in criminal trials violates section 198(1) CPA and may void evidence, warranting retrial in the interest of justice.
Criminal procedure – section 198(1) CPA – mandatory oath or affirmation – evidence given without oath/affirmation amounts to no evidence; nullification of affected proceedings and ordering of retrial where interest of justice so requires (Fatehali Manji principle).
12 May 2022
Court set aside unproved TZS 40,000,000 award, upheld TZS 20,000,000 general damages, and revised occupier status to owner until compensated.
Land law – compensation to outgoing occupiers under a Special Mining Licence – proof of payment required.* Evidence – burden and adverse inference where party fails to call material witnesses or prove alleged payments.* Damages – distinction between general and special damages; special damages must be specifically pleaded and strictly proved.* Revisionary powers – correction of tribunal’s characterization of party’s title where order is inconsistent with pleadings and evidence.
12 May 2022
The applicant's armed robbery conviction upheld: identification valid due to red-handed arrest and hot pursuit.
Criminal law – Armed robbery under section 287A – proof of stealing while armed and use/threat of violence; Identification – red-handed arrest/hot pursuit sufficient to validate identification; Evidence – minor contradictions not fatal; Procedural irregularity – search certificate not read out expunged but oral evidence of search retained; Appellate review – concurrent findings of fact not disturbed absent misapprehension.
12 May 2022
An appeal against refusal to extend time for judicial review is incompetent without leave and is struck out with costs.
Appellate jurisdiction — s.5(1)(c) AJA — refusal to extend time for judicial review requires leave; appeal without leave incompetent; Registrar cannot grant leave; appeal struck out with costs.
12 May 2022
High Court wrongly found appellants' document forged; appeal allowed and High Court decision set aside.
Evidence — Documentary evidence — Allegation of forgery — Comparison of original and carbon copy — Primary Courts: applicable rules of evidence — appellate interference where lower courts' findings are non-concurrent and there is misapprehension of evidence.
12 May 2022
Appeals from the Labour Division are limited to points of law; factual re‑evaluation renders the appeal incompetent.
Labour law – Appeals from Labour Court – section 57 LIA – appeals confined to points of law; factual disputes and re‑evaluation of evidence are outside jurisdiction. Point of law – misapprehension of evidence may qualify where there is failure to evaluate or no evidence, but not where appeal merely seeks re‑weighing of facts. Preliminary objection – competence of appeal – striking out incompetent labour appeals.
12 May 2022
High Court erred in deciding res judicata without hearing parties; appeal allowed and matter remitted for rehearing.
Civil procedure – appeal – appellate court must address grounds of appeal presented; may decide decisive ground but must consider complaints before it. Res judicata – point of law that may be raised at any time but parties must be given opportunity to be heard before determination. Constitutional right to fair hearing – article 13(6)(a) – denial of adequate opportunity to be heard vitiates judgment. Remedy – quash and set aside High Court judgment; remit for rehearing before another judge.
12 May 2022
Applicant's armed-robbery convictions upheld on recent-possession and firearm evidence despite expunged statements.
Criminal law – Armed robbery – Visual identification at night – unreliable identification evidence; Cautioned and extra-judicial statements – improperly admitted and not read out – expunged; Doctrine of recent possession – recovered motorcycle and mobile phone shortly after theft – presumption of guilty where items refer to charged offence; Possession of firearm as corroboration of robbery at gunpoint.
12 May 2022
Revision application struck out for lack of pleaded/attached letters of administration, rendering applicant without standing.
Civil procedure — Representative capacity — Letters of administration must be pleaded and attached to establish standing; failure to do so renders proceedings incompetent and subject to striking out; liberty to refile on production of valid letters.
12 May 2022
High Court lacked jurisdiction without mandatory committal; conviction quashed and matter remitted for proper committal and trial.
Criminal procedure – mandatory committal under s.246(1) CPA – absence of committal order vitiates High Court’s jurisdiction – conviction nullity – remittal for proper committal and retrial.
12 May 2022