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.
85 judgments

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85 judgments
Citation
Judgment date
June 2022
Immediate termination without the 14‑day remedy notice for remediable breaches was premature; the contract remains subsisting.
Contract law – Termination clause – Distinction between breaches permitting immediate termination and remediable breaches requiring 14‑day notice under clause 19(c); Effectiveness of termination notice; Evidence regarding insurance documentation and NEMC permit; Relief — quashing of premature termination and related orders.
29 June 2022
Review dismissed: no error apparent; respondent affirmed lawful owner; purchaser not bona fide; damages upheld.
Review — Rule 66(1)(a): error apparent on face of record; Land law — double allocation and validity of grant; Evidentiary weight — registered certificate v. administrative letters; Bona fide purchaser — duty to search; Attorney General's opinion not binding.
28 June 2022
Payments by a Tanzanian resident to non-residents for services consumed in Tanzania attract withholding tax; 2020 amendment clarified law.
Tax law – Withholding tax on cross-border service payments; source of income determined by where services are consumed/where payer resides; sections 6(1)(b), 69(i)(i) and 83(1)(b) ITA 2004; Finance Act 2016 and 2020 amendments clarificatory not retrospective; precedents – Tullow line of authority.
28 June 2022
Court allowed additional ground on locus standi and ordered High Court to take further evidence on shareholders.
• Civil procedure – Appellate practice – Rule 113(1): leave to add an additional ground of appeal raising jurisdictional issues. • Civil procedure – Rule 36(1)(b): discretionary power to take or direct taking of additional evidence on appeal from High Court exercising original jurisdiction. • Locus standi/shareholding – necessity of conclusive evidence of shareholders for jurisdiction and execution of decree. • Right to be heard – lateness excused where new material evidence emerges post-judgment.
28 June 2022
Failure to file a defence, not nondisclosure of another suit, determines entitlement to set aside an ex parte judgment.
Civil procedure – ex parte judgment – setting aside – requires showing good cause for failure to file written statement of defence. Pleading duty – no obligation to disclose unrelated pending proceedings involving different parties/causes of action when prosecuting an ex parte proof. Legal representation – allegations of counsel’s negligence or lack of update do not necessarily constitute good cause to set aside ex parte judgment. Appellate review – discretionary refusal to set aside an ex parte judgment will not be disturbed absent misdirection in exercise of discretion.
28 June 2022
Stay of execution granted pending appeal after applicant satisfied Rule 11 timing, good cause, loss and security requirements.
Labour law – stay of execution pending appeal – Rule 11 Court of Appeal Rules – timing, good cause, substantial/irreparable loss, and security requirements; bank guarantee as security.
28 June 2022
Revision unavailable where High Court's stay was interlocutory and did not finally determine the suit.
Appellate procedure – Revision – Section 5(2)(d) AJA – Interlocutory/preliminary orders – Stay of proceedings pending determination elsewhere – Finality test: order must finally dispose of parties' rights to be amenable to revision.
28 June 2022
Both parties failed to prove payment or breach on balance of probabilities; appeals dismissed and each party bears its own costs.
Contract/hire-purchase – title passes only on full payment; civil standard of proof – burden on party alleging facts (ss.110–111 Evidence Act); documentary evidence – bank pay-in slips/bank statements necessary to corroborate payment claims; internal account statements (exhibit P3) without corroboration lack legal force; non-production of annexure A2 precludes reliance on it; confiscation lawful if unpaid.
27 June 2022
An execution order committing a person to civil prison is not appealable as of right; revision was improperly invoked, applications struck out.
Civil procedure – Execution of decree – Order for arrest and detention in civil prison – Appealability under section 5(1)(b)(viii) AJA – Revisional jurisdiction – Revision inappropriate where right of appeal exists – Leave to appeal required.
27 June 2022
Trial court must follow s27 CPC and Order XVI and afford a hearing before committing a non‑party witness.
Civil procedure – Committal of witness for non‑attendance – Section 27 Civil Procedure Code and Order XVI rules 10–13,16 – requirement to order security and follow proclamation/arrest warrant procedure – suo motu committal unlawful – right to be heard – civil vs criminal imprisonment – alternative remedy under Penal Code s.124.
27 June 2022
High Court's omission to decide time-bar and raising new issues without hearing parties rendered its judgment null and remitted.
Land law – title dispute – limitation/time bar – jurisdictional objection must be determined first; civil procedure – non-joinder of necessary party – locus standi; natural justice – right to be heard – courts must place new issues on record and hear parties; appellate jurisdiction – revisional power under s.4(2) AJA to quash null judgments.
24 June 2022
Unpleaded repossession defence and excluded witness paragraphs did not vitiate trial; appeal dismissed with costs.
Commercial Court procedure – witness statements and admission of documents; striking out unpleaded paragraphs; admissibility of documentary evidence; pleadings rule – issues must be pleaded; repossession as contractual defence raised late; appellate limitation on unpleaded issues.
21 June 2022
An application for stay of execution is incompetent and unsalvageable if it omits any vital document required by Rule 11(7).
Court of Appeal Rules, r.11(7) – mandatory documents for stay of execution (notice of appeal; decree; judgment/ruling; notice of intended execution) – omission renders application incompetent; overriding objective cannot cure absence of vital documents; application struck out.
21 June 2022
An out-of-time notice of appeal renders the appeal incompetent and will be struck out; attaching the judgment copy is not mandatory.
Civil procedure – Appeal competence – Notice of appeal – Rule 83(2) Court of Appeal Rules 2009 – thirty-day time limit – effect of out-of-time notice; Civil procedure – Requirement to attach copy of High Court judgment – Rule 83(5) not mandatory – delay in obtaining copy not an excuse; Appeals – Valid notice of appeal as jurisdictional prerequisite – failure renders appeal incompetent and liable to be struck out.
21 June 2022
Revision struck out: Court cannot in revision determine receiver’s mandate or order reimbursement without evidence.
Civil procedure — Revision under s.4(3) AJA — Court of Appeal’s remit limited to examining High Court record for correctness, legality and regularity; cannot try factual disputes or receive fresh evidence. Company/secured transactions — Receiver and Manager — Mandate/locus standi to represent company — factual question requiring evidence. Evidence — Documents not tendered/admitted in original proceedings cannot be relied upon in revision. Mediation/consent judgment — Challenging mediator’s recording or judge’s involvement requires appropriate forum and evidence.
20 June 2022
Res judicata bars re‑litigation of an unappealed High Court decision upholding section 36(2) EOCCA in public interest litigation.
Constitutional law – challenge to section 36(2) EOCCA – Article 13(6)(a) – bail and DPP certificate. Civil procedure – res judicata (section 9 CPC) – applicability to public interest and constitutional litigation. Public interest litigation – binding effect of an unappealed High Court decision on subsequent petitions by other interested persons.
17 June 2022
Failure to arraign the appellant as required by law rendered the trial a nullity; conviction quashed and appellant released.
Criminal procedure – Arraignment and plea – Mandatory requirement under section 250 CPA; failure to read information and take plea renders trial a nullity; retrial discretionary – not ordered where it would enable prosecution to fill gaps in evidence; appellate revision under s.4(2) AJA to quash conviction and order release.
17 June 2022
An order refusing leave to seek judicial review is appealable; revisional jurisdiction cannot replace an appeal and application was struck out.
Civil procedure – Revision v appeal – revisional jurisdiction is not an alternative to appeal; limited exceptional circumstances only allow revision. Administrative law – refusal of leave to apply for prerogative remedies (judicial review) is appealable, not revisable. Public procurement – procedural lacunae in statutory remedies do not convert an appealable order into a revisable one.
17 June 2022
High Court breached right to be heard and voir dire omissions invalidated child evidence, undermining the conviction.
Criminal law – appellate procedure – appellate court must not decide issues not raised by parties; breach of right to be heard nullifies judgment; Evidence – child witnesses – voir dire must establish sufficient intelligence and understanding of duty to tell truth before admitting evidence; omission renders evidence invalid and may be expunged; insufficiency of remaining evidence defeats conviction.
17 June 2022
Application for stay of execution held not time-barred where applicant proved service within the 14-day statutory period.
Civil procedure – Stay of execution – Rule 11(4) Court of Appeal Rules (2009) – 14-day limitation from service or awareness of execution notice. Evidence – Proof of service/awareness – reliance on earlier court proceedings must establish actual notice to start limitation period. Judicial discretion – in cases of ambiguous record, applicant’s sworn evidence may be preferred in the interest of justice.
17 June 2022
Copies of unproduced receipts were rightly rejected; the applicant failed to prove loss and the respondent’s counterclaim was upheld.
Evidence Act (sections 61, 65–68) – secondary evidence – copies of documents – notice to produce/originals required before secondary evidence admissible. Civil procedure – burden and standard of proof – section 110 Evidence Act – balance of probabilities. Admissibility – documents in foreign language – requirement for translation and proof of relevance/authenticity. Contract recovery – lender’s counterclaim for outstanding loan where borrower admitted default.
17 June 2022
Changes of assessors resulting in assessors not hearing the whole trial render the Land Tribunal's decision and subsequent appeal a nullity.
Land Tribunal — Composition and mandatory participation of chairman plus two assessors — Sections 5, 7 and 37 Land Tribunal Act. Assessors — An assessor must hear the whole trial to participate in decision-making; assessor changes during trial may vitiate proceedings. Procedural nullity — Improperly constituted Tribunal renders its proceedings and subsequent appeals nullity; retrial de novo required.
17 June 2022
Payment to a former distributor as compensation was not deductible; interest on understated tax was properly imposed.
Tax law – deductibility of expenditure – payment to former distributor for loss of customers – requirement of nexus and expense being "wholly and exclusively" for production of income (s 11(2) ITA); Tax law – understated tax interest – application of s 99(1) where instalments are less than 80% of correct tax; Procedural – distinction between informative correspondence and written application under s 79(2) for extension of time.
17 June 2022
Court granted retrospective extension to serve notice of appeal after excusable mistake, finding no inordinate delay or prejudice.
Civil procedure – extension of time – service of notice of appeal under rule 84(1) – requirement to serve respondent after lodgement. Exercise of judicial discretion guided by Lyamuya factors: reason for delay, length of delay, diligence, prejudice. Retrospective enlargement of time to the date of actual service. Effect of notice of appeal on execution under Tax Revenue Appeals Act/rules.
17 June 2022
Extension of time denied for failure to account delay and because the order was appealable only with leave under land law.
Civil procedure — Extension of time — Judicial discretion — Factors: length of delay, reasons, arguable case, prejudice. Delay and diligence — Forum-shopping and successive incompetent filings do not establish promptness. Illegality ground — Must be apparent on the face of the record to justify enlargement of time. Land disputes — Orders arising from land matters are appealable only with leave under section 47(2) of the Land Disputes Courts Act.
16 June 2022
Appellant's murder conviction quashed for unsafe visual identification and failure to call material witnesses.
Criminal law — murder — requirement to prove guilt beyond reasonable doubt; visual identification — need for caution where identification is at night, under stress or with inconsistent accounts; non-summoning of material witnesses — adverse inference; appellate reappraisal of credibility and findings; unsafe conviction — quashing of death sentence.
16 June 2022
Whether nighttime visual identification by neighbour-eyewitnesses was reliable to sustain murder convictions.
Criminal law – murder – reliance on visual identification – requirements for reliability: familiarity, lighting, duration of observation. Evidence – credibility and consistency of eyewitnesses; material versus non-material contradictions. Criminal procedure – assessors’ directions – need to consider conditions favourable to correct identification. Conviction must rest on prosecution's proof beyond reasonable doubt, not merely weakness of defence. Post-offence conduct as corroborative evidence.
16 June 2022
Amending trial issues without hearing and failing to frame distinct issues vitiated the judgment, necessitating retrial.
Civil procedure — Framing and amendment of issues — Order XIV r.1 & r.5(1) CPC — right to be heard before amendment — failure to frame distinct issues vitiates judgment — retrial ordered; bank liability in cheque clearing and alleged fraud.
16 June 2022
High Court lacked jurisdiction to divide matrimonial assets between Muslim parties; award quashed and record remitted.
Kadhi's Court jurisdiction – Exclusive jurisdiction over division of matrimonial assets between Muslims where there is actual contribution (Kadhi's Court Act); Civil procedure – Misjoinder of causes of action and Order II r.6 CPD; Jurisdictional defect – Proceedings and award made without jurisdiction are a nullity and subject to quashing under Appellate revisional powers (s.4(2) AJA).
16 June 2022
Prosecution failed to prove theft beyond reasonable doubt; audit and banking evidence were unreliable, appeal dismissed.
Criminal law – Theft – Elements of stealing – burden on prosecution to prove dishonest conversion and absence of claim of right beyond reasonable doubt. Evidence – Bank deposits and cash book entries – necessity for independent proof of source of funds. Evidence – Reliability and authenticity of audit reports – inconsistencies may undermine prosecution case. Criminal procedure – Prosecution cannot shift burden of proof to accused.
16 June 2022
Victim’s credible testimony and PF3 sufficed to prove rape; appellate enhancement of compensation without hearing was unlawful.
Criminal law – Rape – Essential element of penetration – Proof by victim’s testimony corroborated by medical PF3 indicating old penetration and pregnancy. Evidence – Delay in reporting sexual assault – Delay does not automatically negate credibility where plausible explanation exists. Medical evidence – Helpful but not indispensable to prove rape; prosecutrix’s evidence may suffice. Civil relief in criminal proceedings – Appellate court must afford parties opportunity to be heard before varying compensation orders.
16 June 2022
An appeal is time-barred if the request for certified copies was made after 30 days and cannot be cured by revisional powers.
Civil Procedure – Limitation – Rule 90(1) & (3) of the Tanzania Court of Appeal Rules, 2009 – requirement to apply for certified copies within 30 days and to serve respondent – certificate of delay invalid if application made after 30 days. Jurisdiction – time bar – limitation is jurisdictional and cannot be assumed or cured by the Court’s revisional powers. Appellate jurisdiction – section 4(2) AJA and overriding-objective (sections 3A, 3B) cannot validate a time-barred appeal.
16 June 2022
The respondents' notice of appeal was struck out for failing to take essential steps to prosecute the appeal.
Court of Appeal — Striking out notice of appeal for failure to take essential steps; Rule 89(2) TCPR 2009; Rule 90(5) — Registrar’s duty to prepare record within 90 days and appellant’s duty to collect/follow up; evidential requirement to show diligence in obtaining record of appeal.
16 June 2022
Appellant properly identified and convicted of rape, but gang-rape conviction quashed and sentence reduced to 30 years.
Criminal law – Rape and gang rape – distinction between presence and active participation; proof beyond reasonable doubt required to convict for gang rape. Identification – caught in flagrante and corroboration by independent witness. Appellate revisional powers – substitution of conviction and variation of sentence under s.4(2) AJA.
16 June 2022
Filing parallel extension applications in different courts is an abuse of process; must seek High Court first.
Appellate procedure — extension of time/leave to appeal — Rule 47(1) and AJA require first application to High Court; concurrent applications in different courts; res sub judice/res judicata; abuse of process/forum shopping; corporate name change and locus standi.
16 June 2022
Failure to serve the copy-request on all respondents renders the appeal time-barred; revision refused absent exceptional circumstances.
Civil procedure — Limitation — Rule 90(1) and (3) Court of Appeal Rules — requirement to serve written application for copies on all respondents — failure to serve disqualifies exclusion period — appeal time-barred; Revisional jurisdiction — section 4(2) AJA — only for exceptional circumstances where no appeal lies — alleged appearance of unqualified advocate is a ground of appeal, not exceptional circumstance.
16 June 2022
Improper post-evidence tendering of key exhibit by prosecutor warranted expungement; convictions quashed for lack of proof.
Criminal procedure — Improper tendering of exhibits by prosecutor after witness evidence — Denial of opportunity for cross-examination — Expungement of exhibit; Chain of custody — handover letter not required within same office; Condition of exhibits due to storage; Legal aid — no duty to inform/provide state-funded counsel unless indigence established and requested; Search — independent witness requirement applies to premises, not person; Appellate judgment — must show reasons and issues for determination.
16 June 2022
16 June 2022
Division of matrimonial assets between Muslim spouses falls within the exclusive jurisdiction of the Kadhi's Court; High Court proceedings were nullity.
Jurisdiction — Kadhi's Court exclusive jurisdiction over Muslim personal law matters including division of matrimonial assets — High Court lacked jurisdiction — jurisdictional defect renders proceedings and judgment a nullity — court's duty to address jurisdiction suo moto even where counsel withdraws objection.
16 June 2022
Interlocutory rulings not appealed cannot form grounds of appeal; LRA s.87(1) grants automatic appeal and missing records may be cured by rule 96(7).
Appeal — interlocutory rulings — non-appealable interlocutory decision; Appellate jurisdiction — leave to appeal — s.87(1) Labour Relations Act confers automatic right of appeal; Civil procedure — record of appeal — omission of drawn order — curable under rule 96(7) by supplementary record.
16 June 2022
Appeal dismissed: Court has jurisdiction only on questions of law under section 25(2) TRAA; factual disputes are not entertainable.
Tax appeals — jurisdictional limitation — appeals from Tax Revenue Appeals Tribunal to Court of Appeal confined to questions of law (s.25(2) TRAA); appellate competence — Court will not re-evaluate factual findings; procedural irregularity — introducing new issues in submissions is impermissible; taxation — burden to challenge assessments rests on taxpayer (not re-opened here).
16 June 2022
Immediate victim identification and corroborative evidence can sustain a rape conviction despite no identification parade.
Criminal law – Rape – proof of age, penetration and identity – victim identification at earliest opportunity and arrest nearby can dispense with identification parade. Criminal procedure – appellate review – failure of lower courts to consider defence entitles Court of Appeal to consider defence and re-evaluate evidence. Evidence – medical report (PF3) – absence of file number or lack of bleeding not necessarily fatal to prosecution's case; medical findings can corroborate victim's account. Defence – alibi assessed against positive identification and surrounding circumstances; credibility may be rejected.
16 June 2022
Failure to serve motion documents within 14 days under rule 55(1) renders an application incompetent; oral explanations cannot cure that defect.
Civil procedure — Court of Appeal Rules, r.55(1) — mandatory service of notice of motion, affidavit and supporting documents within 14 days — non-compliance renders application incompetent; affidavits must contain reasons for delay — oral submissions not substituting for affidavit (afterthoughts).
16 June 2022
A judgment on admission that does not dispose of all claims is interlocutory and not appealable under section 5(2)(d) AJA.
Appealability — interlocutory orders; judgment on admission (Order XIV r.6 CPD) — does not dispose of all rights; section 5(2)(d) Appellate Jurisdiction Act — appeal only where interlocutory order finally determines the suit; nature-of-order test (Bozson test) applied.
16 June 2022
An invalidated certificate of delay has no legal effect; supplementary record with one valid certificate is not fatally defective.
Civil procedure – supplementary record of appeal – Rule 96(7) – purpose to complete record. Civil procedure – certificate of delay – legal effect of a certificate previously declared invalid; two operative certificates cannot co-exist. Appellate practice – preliminary objection – competence of appeal – defects and curability.
15 June 2022
A preliminary limitation objection is premature where disputed facts of concealment engage section 26 of the Limitation Act.
Limitation law — section 26, Law of Limitation Act — fraud or mistake postponing commencement of limitation period. Judicial review/prerogative orders — certiorari, mandamus, prohibition — computation of time for application. Civil procedure — preliminary objection — Mukisa Biscuits principle: objections raising contested facts are premature. Service and concealment — effect of alleged deliberate non‑service on accrual of right to litigate.
15 June 2022
Stay refused: applicant failed to show substantial loss and gave no firm undertaking to provide security.
Court of Appeal — Stay of execution — Rule 11(3), (4) and (5) of the Court of Appeal Rules — cumulative requirements: substantial loss and security; affidavit must provide particulars — submissions not substitute for evidence; application dismissed for failure to give firm undertaking to furnish security.
15 June 2022
Applicant's challenge to mandatory death sentence under s197 is barred by res judicata; appeal dismissed.
Constitutional law – Death penalty – Mandatory imposition under s.197 Penal Code – Challenge to constitutionality – Res judicata – public interest litigation – Article 30(2) saving clause – remedy for partial invalidity (reading down) left undecided.
15 June 2022
Claims to deceased spouse's matrimonial assets must be pursued in probate/administration, not a matrimonial suit.
Matrimonial property – Proper forum for distribution after death; Probate and Administration jurisdiction; Law of Marriage Act s.76 and s.114; administratrix properly impleaded as estate representative; procedural misjoinder – remedy of nullification and quashing of proceedings.
15 June 2022
A divorce petition lacking a valid conciliatory board certificate is incompetent and renders resultant orders a nullity.
Family law — Divorce — Mandatory pre‑petition conciliatory board certificate (Law of Marriage Act ss.101, 106(2); Reg.9(2)) — Board’s duty to hear parties and set out findings (s.104(1),(5)) — Certificate that merely repeats allegations is invalid — Absence of valid certificate is jurisdictional, rendering divorce proceedings nullity.
14 June 2022