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.
26 judgments

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26 judgments
Citation
Judgment date
December 2020
Broken chain of custody and an unauthorized valuation report rendered the prosecution's case unproven beyond reasonable doubt.
Criminal law – Wildlife offences – unlawful possession of government trophy (elephant tusks) – requirement to prove possession beyond reasonable doubt. Evidence – chain of custody – PGO No.229 – necessity of a clear paper trail, custody, transfer and marking/identification of exhibits. Evidence – relaxation of strict chain-of-custody rules where item cannot easily be tampered with; application depends on circumstances. Statutory requirements – Trophy Valuation Report (s.86(4) Wildlife Act) – who may sign/prepare valuation; probative value and admissibility. Remedy – expungement of inadmissible evidence and quashing of conviction where prosecution case fails.
17 December 2020
August 2020
Conviction for rape upheld but 30‑year sentence quashed because, aged 18, only corporal punishment applied.
Criminal law – Rape of a child – Proof of penetration and age: victim’s testimony and medical corroboration; PF3 expunged if not read over; identification: victim’s description and accused’s conduct; failure to call non‑essential witness not fatal; omission of punishment sub‑section curable under s.388 CPA; sentence illegal where s.131(2)(a) mandates corporal punishment for a boy aged ≤18.
28 August 2020
Rape conviction upheld: defective charge curable, identification and victim’s credible testimony sufficient; PF3 expunged.
Criminal law – Rape – Identification by victim and witness who knew accused – Charge irregularity – omission to cite specific subsections curable under s.388 CPA if no prejudice – PF3 read before admission expunged – Victim’s evidence as proof of penetration.
28 August 2020
Review application dismissed as a disguised appeal; review limited to narrow rule 66 grounds, not merits.
Appellate procedure – Review jurisdiction – rule 66(1) – review not a disguised appeal; limited to manifest error apparent on face of record or deprivation of hearing. Criminal procedure – Alleged failure to address accused under section 291(3) CPA and admission of postmortem report – such complaints, if not raised on appeal, are appellate issues not proper in review. Appellate Jurisdiction Act s.4(4) – omission to cite is undesirable but not necessarily fatal where Court has jurisdiction.
26 August 2020
Conviction for grave sexual abuse upheld; name variance and missing arresting officer not fatal to prosecution's case.
Criminal law – grave sexual abuse – proof beyond reasonable doubt – eyewitness evidence of insertion of penis into mouth of 14‑month‑old child; Evidence Act – section 127 (competence of child witnesses) – 14‑month‑old incapable of testifying; Evidence Act – section 143 – no fixed number of witnesses required; Criminal procedure – variance in victim's name – not fatal where no prejudice and no cross‑examination; Appellate review – concurrent findings of fact will not be disturbed absent misdirection or miscarriage of justice.
20 August 2020
Failure to serve the application for copies prevents reliance on certificate of delay and justifies striking out notice of appeal.
Civil procedure — Court of Appeal Rules 2009 — Rule 90(1) and (3): requirement to serve written application for copies of proceedings; certificate of delay; Rule 89(2): striking out notice of appeal for failure to take essential steps; service of request for record as essential step; awaiting unrelated extension application not an excuse.
19 August 2020
Mis‑citation in charge curable; victim’s credible evidence and corroboration upheld rape conviction.
Criminal law – Rape – Sufficiency of evidence: victim’s testimony proving penetration and lack of consent; corroboration by witness and medical evidence; Charge‑sheet defects – Mis‑citation of statutory subparagraph curable under s.388(1) CPA where particulars clear and accused not prejudiced; Appellate review – concurrent findings of fact not disturbed absent misdirection; Procedure – new grounds introduced at Court of Appeal barred by rule 72(2).
19 August 2020
Failure to consider defence justified appellate reassessment; conviction upheld and 30‑year sentence substituted by life imprisonment.
Criminal law – second appeal – appellate intervention where lower courts omitted to consider defence; Evidence – documents admitted must be read out in court before reliance (expunge if not); Sexual offences against children – victim's evidence corroborated by medical and supporting witnesses can suffice to prove penetration and non-consent; Evidence Act s.143 – no fixed number of witnesses; Sentencing – s.154 Penal Code as amended by Law of the Child Act: life imprisonment for offences against victims under 18.
18 August 2020
Conviction quashed where prosecution failed to prove recent possession and High Court judgment was a nullity.
Criminal law – armed robbery – recent possession doctrine; sufficiency of identification and proof of ownership; chain of custody of exhibits; duty to call available independent witnesses (petrol attendants) – adverse inference; defects in seizure documentation; requirements for appellate judgment under section 312(1) CPA; revisional powers under section 4(2) AJA.
18 August 2020
July 2020
Court found the house on Plot 16; respondent was a trespasser; appellant awarded TZS15M, eviction and injunction.
Land law – trespass to land – disputed location of property – locus in quo visit and certified survey plan establishing location (Plot No.16). Possession and title – buyer in possession – trespass actionable per se despite honest mistake. Damages – failure to prove special damages; award of general damages (TShs 15,000,000). Remedies – eviction and perpetual injunction; costs. Procedure – use of additional evidence via locus in quo under Court of Appeal Rules to resolve factual dispute.
24 July 2020
April 2020
Delay caused by the Registrar's failure to furnish certified proceedings excuses failure to lodge an appeal; notice of appeal not struck out.
Civil procedure — strike out of notice of appeal — Rule 89(2) — essential steps to prosecute appeal — request for certified proceedings from Registrar — delay caused by Registrar’s inaction — non-retrospective application of Rule 90(5) where not pleaded.
2 April 2020
Delay caused by court processes (leave and certified copies) amounted to good cause for extension of time to appeal.
Civil procedure – Extension of time under Rule 10 – Good cause requires explanation of delay; court delays in granting leave and supplying certified copies can justify extension; respondent's failure to file affidavit limits challenge to law only.
2 April 2020
Improperly admitted statements expunged, but remaining circumstantial evidence upheld convictions and death sentences.
Criminal law – Evidence – Improper admission of cautioned and extrajudicial statements – trial within a trial – expungement; Circumstantial evidence – principles and standards – "last seen with deceased" rule; Conduct after the incident (flight, disposal/sale of victim's property) as corroboration; Materiality of minor contradictions.
2 April 2020
Whether a notice of appeal should be struck out for failing to take essential steps and for not serving a copy request.
Court of Appeal — Civil procedure — Striking out notice of appeal — Failure to take essential steps under Rule 89(2) — Time limits for instituting appeal under Rule 90(1) — Exception for written, served request for copies — Service requirements and exclusion of time — Sickness not a substitute for applying for extension of time.
2 April 2020
Assessors’ cross-examination and insufficient, contradictory circumstantial and expert evidence vitiated the murder conviction.
Criminal law – murder – circumstantial evidence – requirement of complete chain excluding all reasonable hypotheses; assessors’ role – assessors must not cross-examine witnesses (section 177 Evidence Act) – cross-examination by assessors vitiates trial; exhibits – necessity to read admitted exhibits aloud to accused; failure to call crucial witnesses – adverse inference; retrial – when not in interest of justice.
2 April 2020
March 2020
Failure to sum up material evidence to assessors vitiated the trial; conviction quashed and retrial ordered.
Criminal procedure – Assessors’ involvement – Duty to sum up evidence to assessors (s.265, s.298(1) CPA) – Inadequate summing up renders trial without aid of assessors and is a nullity – Remedy: quash conviction and order retrial (s.4(2) AJA).
27 March 2020
Extension of time granted where applicant accounted for delay and indicated intended ground (manifest error); Single Justice must not decide substantive merits.
Criminal practice — extension of time — Rule 10 Court of Appeal Rules — good cause assessed by factors including length and reasons for delay, arguability and prejudice. Review procedure — Rule 66(1) — indication of intended grounds (manifest error on the face of the record) suffices at extension stage; detailed proof of merits not required. Limitation on Single Justice — must not determine substantive merits when deciding extension applications.
26 March 2020
Certified copy of term deposit rightly excluded; applicant failed to prove existence of the fixed deposit on balance of probabilities.
Evidence Act (ss. 61, 65–68) – best evidence rule – proof of contents of documents – secondary evidence – requirement to serve notice or procure original holder's attendance; Banking law – alleged fixed deposit – necessity of primary documentary proof for written agreements; Civil procedure – standard of proof – balance of probabilities; Adverse inference – no duty to call witnesses where respondent denies transaction; First appellate reappraisal – rule 36(1)(a).
26 March 2020
Applicant failed to show good cause for extension to lodge review due to unexplained delay; application dismissed.
Civil procedure – Extension of time – Rule 10 Court of Appeal Rules – requirement to show good cause; must account for each day of delay; length and reason for delay and arguability relevant. Review procedure – Rule 66(3) – copy of judgment to be annexed; late supply may justify some delay but applicant must explain all periods. Jurisdiction – Single Justice on extension applications should not probe substantive merits of intended review.
26 March 2020
A defective certificate of delay that omits exclusion of days or records a wrong date is vitiated and must be rectified and re‑lodged.
Civil procedure – certificate of delay – defective certificate – failure to exclude aggregate days and incorrect application date – error vitiates certificate. Court of Appeal Rules (Rule 90(1), Rule 4(2)(a)(b)) – rectification and lodging of supplementary record of appeal.
26 March 2020
A certificate of delay with material errors is vitiated; court allowed rectification and ordered lodging of a rectified certificate within 30 days.
Civil procedure – Certificate of delay – Material errors (wrong application date; failure to exclude days under Rule 90(1)) vitiate certificate; rectification permitted; lodging of rectified certificate as supplementary record of appeal; responsibility of Registrar and duty of party to seek correction.
26 March 2020
Assessor cross‑examination and improperly read exhibits rendered trial unfair; convictions quashed for insufficient corroborated evidence.
Criminal procedure – assessors’ role – assessors must not cross‑examine witnesses (s.177 Evidence Act); preliminary hearing formalities – cautioned statements and exhibits must be read over to accused (s.192(3) CPA); sufficiency of evidence – unreliable eyewitness testimony and uncorroborated cautioned statement cannot sustain a murder conviction; remedy – vitiated proceedings may be nullified but retrial is discretionary and not automatic.
25 March 2020
Appellant's murder conviction and death sentence upheld on cumulative circumstantial evidence, despite expunging the unread Post-Mortem report.
Criminal law – Murder – Circumstantial evidence – Last seen with victim and possession of suspected weapon – Chain of circumstantial facts must be complete and point irresistibly to guilt; Post-Mortem report must be read out when tendered; minor inconsistencies in dates immaterial where charge correctly pleads assault date.
24 March 2020
Review application dismissed: complaints were re‑argument of appeal, not a manifest error on the face of the record.
Appellate review — Review jurisdiction under s.4(4) AJA and Rule 66(1) — Manifest error on face of record — Standard requires obvious, self-evident mistake — Review distinct from appeal — Mesne profits and set-off where partial payment established.
20 March 2020
Failure to comply with section 231(4) CPA in denying defence witnesses rendered subsequent proceedings a nullity; trial to resume.
Criminal procedure – Right of accused to call witnesses – Section 231(1) and (4) CPA – Trial court must inquire into absence of defence witnesses, compel attendance or record reasons – Failure renders proceedings a nullity – Appellate court’s revisional powers to quash and order recommencement of trial.
19 March 2020
Where retrenchment is substantively fair but procedurally defective, courts may award less than twelve months' compensation.
Labour law – retrenchment – operational requirements – validity and fairness of termination for renovation and safety reasons. Labour law – retrenchment procedure – section 38 E.L.R.A. – requirement to give notice, disclose information and consult; failure to issue formal retrenchment notice and inadequate consultation. Employment compensation – unfair termination – discretion to award less than statutory twelve months' remuneration where unfairness is procedural only.
18 March 2020