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.
828 judgments

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828 judgments
Citation
Judgment date
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
Presence at scene and credible seizure evidence upheld conviction for trafficking despite procedural delays.
Criminal law – Narcotic drugs – trafficking – admissibility and disposal of perishable exhibits under PGO 229:25; seizure certificates and emergency searches (s.42 CPA); chain of custody – delays in chemist’s report – preservation versus documentary perfection; credibility of witnesses and association with vehicle.
6 October 2022
Variance in particulars of the charge was not fatal where essential elements of armed robbery were proved beyond reasonable doubt.
Criminal law — Armed robbery — Essential ingredients under section 287A — Variance between charge sheet and evidence not fatal if ingredients proved — Identification and arrest at scene — Proper charging under section 22(1)(a) Penal Code.
6 October 2022
Tenant failed to prove lease alteration and, after lease expiry, unlawful occupier was not entitled to notice or compensation.
Tenancy law – expiry of lease and status thereafter – unlawful occupation/trespass.* Eviction – service of notice – constructive/service to agent and local government offices; affixation at premises.* Evidence – allegations of fraud/alteration of documents require higher degree of proof than ordinary civil claims; onus on alleging party.* Remedies – unlawful occupier not entitled to notice or compensation for forcible eviction.
6 October 2022
Trespass conviction upheld where complainant’s title was confirmed and a locus in quo visit was unnecessary.
Criminal law – Criminal trespass – Effect of non-execution of civil decree on criminal proceedings – Law of Limitation not applicable to criminal prosecutions; locus in quo inspections unnecessary where location and possession are undisputed.
6 October 2022
Child’s unsworn evidence improperly received and, with insufficient remaining proof and unexplained delay, conviction was quashed.
Evidence Act s.127 – Child witnesses – requirement to test understanding of oath before accepting promise to tell the truth; non‑compliance renders testimony inadmissible. Criminal law – sufficiency of evidence – conviction cannot rest on inadmissible child evidence; hearsay and medical findings absent identification are insufficient. Criminal procedure – unexplained delay in arraignment may create reasonable doubt and undermine prosecution case. Trial evaluation – appellate scrutiny of whether defence and credibility issues were properly considered.
6 October 2022
Appellate court upheld rape conviction: victim’s testimony and medical evidence sufficient; omission of time in charge not fatal.
Criminal law – Sexual offences – Rape of a girl under 18 – Proof requires penetration, age and identity – Victim’s evidence and medical corroboration. Identification – Prior familiarity can render descriptive omissions immaterial. Evidence – Minor inconsistencies or variances in dates are immaterial if they do not affect central prosecution story. Criminal procedure – Particulars of time in a charge are not always required; omission is not fatal unless time is of the essence. Appellate review – Concurrent findings of fact will not be disturbed absent misapprehension or injustice.
6 October 2022
Extension of time under rule 10 is discretionary and not time-barred; application struck out after applicant conceded time-barred leave application.
Appeal procedure – extension of time – rule 10 Court of Appeal Rules – application for extension is governed by good cause and Court's discretion; rule 45 (time for leave to appeal) inapplicable to extension applications; application struck out where applicant conceded underlying time-barred status.
5 October 2022
An application under Rule 10 is not time‑barred; the applicant must show good cause and the grant is discretionary.
Civil procedure – Extension of time – Rule 10 Court of Appeal Rules – Application cannot be time‑barred – Good cause required – Discretionary remedy – Jurisdictional objection under Rule 45.
5 October 2022
Victim's credible testimony and medical corroboration sustained the appellant's convictions for rape and sodomy.
Sexual offences – child complainant – credibility and identity of assailant; Corroboration by medical evidence (PF3/Exhibit P.1); Delay in reporting – threats and child's age; Concurrent factual findings – limited interference by appellate courts; Failure to cross-examine crucial witnesses may amount to acceptance of evidence.
5 October 2022
Conviction for unnatural offence upheld; procedural defects curable and sentence lawfully enhanced to life imprisonment.
Criminal procedure — curability of defects in a charge under section 388 CPA; failure to furnish police statement under section 9(3) CPA; Evidence Act s.127(2) — reception of child witness evidence and inquiry into understanding of oath; admissibility and corroborative weight of medical report in sexual offences; material variance between charge and evidence; mandatory life sentence under Penal Code s.154(2) where victim is under 18.
5 October 2022
Suo motu dismissal at FPTC denied the appellant's constitutional right to be heard; appeal allowed and matter remitted.
Civil procedure – Final pre-trial conference – Court raising competence sua motu – requirement to afford parties opportunity to be heard under Article 13(6). Constitutional law – right to be heard (audi alteram partem) – procedural fairness where judge raises legal issues not previously argued. Probate & administration – overlap of probate proceedings with civil suit raising competence questions. Remedy – quashing suo motu dismissal and remitting record for continuation at prior stage.
5 October 2022
Ignorance of new e‑filing rules and administrative delays do not amount to sufficient cause for extension of time.
Civil procedure — Extension of time — "Sufficient cause" — Applicant must account for all days of delay; ignorance of procedural rule (electronic filing) and administrative delay (practicing certificate/Tax Clearance) do not constitute good cause; affidavit evidence must be properly placed before the court.
5 October 2022
Unpleaded contract cannot be relied on; commercial interest must be proved, court awarded 12% decretal interest.
Civil procedure – pleadings – cause of action must be pleaded; parties bound by pleadings; evidence extraneous to pleadings may be ignored. Contract – contractual dispute resolution clauses – exhaustion of agreed mechanisms; court may not determine remedies under a contract that was not pleaded. Commercial law – mercantile practice entitles commercial debts to interest, but specific commercial rate must be proved; decretal (court) rate may be awarded where commercial rate is unproven.
5 October 2022
Alleged insanity and voluntary intoxication did not negate rape conviction; life sentence reduced due to victim age uncertainty.
Criminal law – Alleged insanity of accused – Procedure under CPA ss.216–218; medical report vs. court findings; voluntary intoxication/self‑induced state not a defence to negate intent in sexual offences; admissions/confessions as strong evidence; sentence mitigation where victim's age is in dispute.
4 October 2022
Summary judgment in mortgage enforcement cannot be entered against non-parties to the mortgage; denial of hearing nullifies the decision.
Civil procedure – Summary suits in mortgage enforcement – only parties to the mortgage deed may be impleaded and subjected to summary judgment; guarantors/non-parties should not be included. Constitutional right to be heard – denial renders decision nullity. Statutory interpretation – plain meaning rule applies to procedural provisions.
4 October 2022
Summary procedure under Order XXXV cannot be used against guarantors who are not parties to the mortgage; judgment set aside.
Civil procedure — Summary procedure (Order XXXV) — Suits arising out of mortgages — Applicability only against parties to mortgage deed; Guarantees vs promissory notes — distinct legal regimes (LCA vs BEA); Right to fair hearing — defendants condemned without leave to appear — summary judgment set aside.
4 October 2022
Only a grantee of probate or letters of administration may sue for a deceased's estate; respondent lacked standing.
Probate and Administration of Estates Act (Cap.352) – section 71 – only grantee of probate or letters of administration may sue as representative of a deceased's estate. Intermeddling – executor of his own wrong – sections 16 and 17 – liability to rightful executor/administrator, legatee or creditor. Locus standi – absence of administrator or probate bars private persons from suing to recover or administer estate assets.
4 October 2022
A conditional stay of execution was granted pending appeal where the applicant showed risk of substantial loss and undertook to provide bank guarantees.
Court of Appeal — Stay of execution — Rule 11(5) Tanzania Court of Appeal Rules — requirement of substantial loss and security — undertaking to furnish bank guarantee — balance of convenience — conditional stay pending appeal.
3 October 2022
High Court lacked jurisdiction where respondent was a specified public corporation requiring leave under the Bankruptcy Act.
Public corporations – Specified public corporation declared under GN No.33/1997 – PSRC/Treasury Registrar as official receiver – Application of Bankruptcy Act – Section 9(1) mandatory leave to sue or be sued – Competence and jurisdiction – Counterclaims by specified public corporations require involvement of receiver.
3 October 2022
September 2022
A suit filed against a deceased person is a nullity and should be struck out, not dismissed.
Civil Procedure – Suit instituted against deceased person – nullity – incompetent proceedings to be struck out, not dismissed; Order 1 Rule 10(1) substitution inapplicable; costs not warranted where suit is nullity and procedural handling was erroneous.
30 September 2022
Conviction quashed where visual and voice identification were unreliable and the cautioned statement was inadmissible.
Criminal law – visual identification – identification at night and in chaotic circumstances requires strict scrutiny; voice identification unreliable; cautioned statements recorded in presence of other officers inadmissible – standard of proof beyond reasonable doubt.
30 September 2022
Penalty omission was curable; credible complainant testimony and medical/eye‑witness evidence sustained convictions.
Criminal law – Sexual offences – Rape and sodomy – Complainant’s testimony as central evidence and may suffice if credible and consistent. Criminal procedure – Particulars of offence – Omission of specific penalty provision in charge curable under section 388 CPA where no prejudice. Criminal procedure – Trials involving sexual offences – Section 186(3) CPA (in camera) intended to protect victims; breach does not automatically vitiate proceedings absent shown prejudice. Evidence – Corroboration by eyewitnesses and medical report supports convictions.
30 September 2022
Review application dismissed for failing to show a manifest error on the face of the record.
Civil procedure – Review under Rule 66(1)(a) – Manifest error on the face of the record – Requirement to identify an obvious, patent mistake; review not a rehearing or re-assessment of evidence.
29 September 2022
Cautioned statement recorded with other officers vitiated; uncorroborated co‑accused evidence insufficient—appellant's conviction quashed.
Criminal law – Admissibility of cautioned statements – voluntariness and right to privacy; cautioned statement recorded in presence of other officers vitiates confession. Evidence of co‑accused requires corroboration; uncorroborated recent‑possession link insufficient. Proof beyond reasonable doubt — conviction quashed when key evidence expunged.
29 September 2022
Stay of execution granted pending appeal where application was timely, security offered and drawn order sufficed as the decree.
Stay of execution — Rules 11(4), 11(5) & 11(7) CA Rules — timeliness, risk of substantial loss, security and accompanying documents — drawn order as decree — Court’s power to stay execution of subordinate court/officer’s decree upheld on High Court reference.
29 September 2022
Proceedings conducted without a section 256A transfer are a nullity; conviction quashed and matter remitted for proper retrial.
Criminal procedure – Transfer of cases under section 256A Criminal Procedure Act – transfer must be issued before plea taking and preliminary hearing; absence of transfer vitiates jurisdiction. Overriding objective – cannot cure mandatory jurisdictional defects. Revisional powers – quash proceedings, conviction and sentence; remit information to High Court for retrial.
29 September 2022
Conviction quashed where night‑time visual and voice identification were unreliable and guilt was not proved beyond reasonable doubt.
Criminal law – Identification evidence – Visual identification at night requires proof of source, intensity and coverage of light; bare assertions insufficient. Criminal law – Identification by voice – generally unreliable and must be treated with caution. Evidence – Proof beyond reasonable doubt – where identification is unsafe conviction cannot stand. Sentencing – Unnatural offence against a child under eighteen attracts life imprisonment (noted but rendered moot by acquittal).
29 September 2022
Appellant's challenge failed: lawful impromptu search, intact chain of custody, and sufficient proof of control of room; appeal dismissed.
Criminal law – possession of narcotic drugs – legality of impromptu search under s.42 CPA – chain of custody of exhibit – proof of occupancy/control of premises – failure to cross‑examine and afterthought defence – role and directions to assessors.
29 September 2022
Failure to sum up to assessors and denial of right to challenge assessors vitiated the trial; retrial ordered.
Criminal procedure – assessors – mandatory requirement to sum up to assessors under s.298(1) Criminal Procedure Act – failure to sum up and denial of accused’s right to object to assessors are fatal irregularities – proceedings nullified – retrial ordered.
29 September 2022
Extinguishing a person's land title without making them a party and affording a hearing violates Article 13(6)(a) and is a nullity.
Constitutional law – right to a fair hearing (Article 13(6)(a)) – person not made party and not heard – decision affecting property rights nullity. Civil procedure – joinder of necessary parties – failure to join interest-holder vitiates judgment. Appellate jurisdiction – exercise of revisional powers under section 4(3) AJA – nullification, quashing and order for fresh proceedings. Natural justice – audi alteram partem rule applied in land disputes.
29 September 2022
An appellate tribunal sitting as first appellate court must determine the appeal to finality, not remit undetermined grounds to the trial Board.
Tax appeals – appellate jurisdiction – first appellate tribunal must determine appeals to finality and not remit undetermined grounds to the trial Board. Civil Procedure Code s.76(1),(2) – appellate court powers to determine case finally and to exercise powers of trial court where appropriate. Appellate review – distinction between credibility issues and proper inferences from facts; appellate court may decide factual inferences. Appellate Jurisdiction Act s.4(2) – revisional powers to cure procedural anomalies and remit for proper judgment.
29 September 2022
Conviction for drug trafficking upheld; unsworn witness evidence expunged and sentence commencement date corrected.
Criminal law — narcotics trafficking — sufficiency of particulars in information (s.132 CPA); sworn evidence requirement (s.198(1) CPA) — unsworn testimony expunged; independent witnesses — law‑enforcement officers may be independent; exhibits — contents must be read out after admission; alibi notice requirements (s.194(4)–(6) CPA) — late alibi may be accorded no weight; sentencing — sentence cannot run from date of arrest, must run from conviction date.
29 September 2022
Whether a notice of appeal can be struck out for failure to take essential steps where Registrar delays supplying court records.
Civil procedure – strike out under Rule 89(2) – whether some essential step was not taken. Procedure – essential steps to further an appeal – case‑specific, depends on facts and nature of appeal. Registrar’s duties under Rule 90(5)(1) – preparation and delivery of certified copies within 90 days and appellant’s duty to collect. Effect of G.N. No. 362 of 2017 and G.N. No. 344 of 2019 – procedural amendments applicable retrospectively.
29 September 2022
The appellant's armed robbery conviction was upheld on credible eyewitness evidence despite missing exhibit and phone-provider testimony.
Criminal law – Armed robbery – sufficiency of prosecution proof by eyewitnesses; admissibility and effect of non-tendered exhibits; calling of mobile service providers not always necessary; credibility and minor discrepancies; no legal requirement to remind accused of charge before judgment.
28 September 2022
The appellant's convictions for sexual offences against a 12-year-old were upheld as the victim's credible, corroborated evidence proved the case beyond reasonable doubt.
Criminal law – Sexual offences – Indecent assault and unnatural offence against a child under 14 – Proof beyond reasonable doubt; victim’s testimony and corroboration. Evidence – Proof of age of a child – by parent or child’s own testimony; requirement satisfied. Evidence Act s.127(2) – Child of tender age must promise to tell the truth – compliance established. Witness credibility – coherence, consistency and corroboration as bases for appellate acceptance of trial findings.
28 September 2022
Non‑compliance with s.234 CPA and s.127(2) Evidence Act rendered conviction unsafe; appeal allowed and release ordered.
Criminal procedure – substitution of charge – non‑compliance with s.234 CPA renders subsequent proceedings a nullity; Evidence – child witness competence – s.127(2) Evidence Act requires testing before taking evidence without oath; Medical evidence/PF3 – establishes sexual assault but not perpetrator identity; Retrial – ordered only if interests of justice require it.
27 September 2022
Appeal allowed: victim's inconsistent accounts and failure to call material witnesses undermined the prosecution's case.
Criminal law – Sexual offences – Credibility of victim – inconsistent statements and delay in naming suspect as undermining reliability. Evidence – Failure to call material witnesses (guest house attendant and sheltering host) – adverse inference against prosecution. Appellate review – Second appeal interference where lower courts misapprehended substance, nature or quality of evidence. Proof beyond reasonable doubt – reliance on victim’s evidence must be cautious where inconsistencies exist.
26 September 2022