Court of Appeal of Tanzania

This is the highest level in the justice delivery system in Tanzania. The Court of Appeal draws its mandate from Article 117(1) of the Constitution of the United Republic of Tanzania. The Court hears appeals  on both point of law and facts for cases originating from the High Court of Tanzania and Magistrates with extended jurisdiction in exercise of their original jurisdiction or appellate and revisional jurisdiction over matters originating in the District Land and Housing Tribunals, District Courts and Courts of Resident Magistrate. The Court also hears similar appeals  from quasi judicial bodies of status equivalent to that of the High Court. It  further hears appeals  on point of law against the decision of the High Court in  matters originating from Primary Courts. The Court of Appeal also exercises jurisdiction on appeals originating from the High Court of Zanzibar except for constitutional issues arising from the interpretation of the Constitution of Zanzibar and matters arising from the Kadhi Court.

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

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57 judgments
Citation
Judgment date
December 2021
The Court struck out the DPP's appeal as incompetent after a Constitutional Court ruling removed the DPP's right to appeal interlocutory orders.
Criminal procedure – competence of appeal – Whether the DPP may appeal interlocutory or preliminary orders after Constitutional Court declared section 6(2) AJA partially void. Interpretation of statutes – retrospective effect – Procedural changes and judicial decisions apply retrospectively to pending cases. Evidence – admissibility/use of CCTV/CD evidence – trial judge’s management of witness testimony (issue not determined due to lack of jurisdiction).
23 December 2021
Non‑compliance with statutory assessors’ participation and written‑opinion requirements nullifies tribunal proceedings and warrants retrial.
Land procedure — District Land and Housing Tribunal — mandatory composition and participation of assessors — requirement for assessors’ written opinions under Regulation 19(2) and section 23(2) — failure to comply is fatal and renders proceedings a nullity — appellate power to nullify and order retrial.
3 December 2021
High Court proceedings after a pending notice of appeal and without mandated assessors are null; matter remitted to recommence.
Civil procedure – jurisdiction – effect of a notice of appeal: once a notice of appeal to the Court of Appeal is lodged and not withdrawn, the High Court ceases to have jurisdiction to proceed. Procedure in Land Division – assessors – Rule 5F/5G (GN. No. 63 of 2001 as amended by GN. No. 364 of 2005): failure to indicate assessors' involvement or parties' choice vitiates proceedings. Appellate powers – revisional jurisdiction under s.4(2) of the Appellate Jurisdiction Act to quash and remit proceedings tainted by jurisdictional or procedural irregularities.
3 December 2021
Administrator's suit upheld: no time-bar, administrator had locus standi, marital issue not properly pleaded.
Land law – limitation – accrual of cause of action – Item 22, First Schedule, Law of Limitation Act; action not time‑barred where cause accrued on eviction. Pleadings – parties bound by pleadings; unpleaded factual issues (e.g. marital status) cannot be raised late. Probate/administration – powers of administrator appointed by Primary Court include collecting estate assets and bringing/defending proceedings (Fifth Schedule, MCA). Locus standi – administrator has standing to sue for matters concerning the deceased's estate even if particular property is not itemized in letters.
3 December 2021
Failure to sum up and to direct assessors on vital law vitiated the trial; conviction quashed and retrial ordered.
Criminal procedure – trial with assessors – mandatory duty to sum up evidence and direct assessors on vital points of law (s.298 CPA); failure renders trial a nullity; retrial in interests of justice; chain of custody and ingredients of offence directions essential.
3 December 2021
Omitted drawn orders are mandatory for a competent appeal, but Court may allow a supplementary record under Rule 96(7).
Civil procedure — Appeal — Record of appeal — Rule 96(1)(h)&(i) (decree/order and order giving leave to appeal) — omission renders record incomplete — Rule 96(7) — Court's discretion to allow supplementary record of appeal — overriding objective limited where mandatory documents are absent.
3 December 2021
Inadequate summing up to assessors vitiated the trial, leading to quashing of conviction and remittal for re-summing up or retrial.
Criminal procedure — duty of trial judge to sum up to assessors; assessors’ opinions must be informed — omission to address vital points (legality of arrest/search, seizure certificate, chain of custody, ingredients of offence, contradictions, burden/standard of proof) vitiates trial — conviction quashed and proceedings remitted for re-summing up or retrial under s.299 CPA.
3 December 2021
Nullification of irregular duplicate titles leaves land with original joint purchasers; subdivision and re-registration require joinder of non-parties.
Land law — competing titles — irregular registration and duplicate certificates — nullification of titles where original joint owners did not approve transfer; procedure — re-surveying, subdivision and registration cannot affect non-parties without joinder and hearing; remedy — dismissal of suit where neither claimant has lawful title.
3 December 2021
Admission of killing; malice aforethought proved by weapon, head wounds, forceful injuries and post-offence conduct; appeal dismissed.
Criminal law – Murder – Malice aforethought – Factors to infer intent (weapon, force, part of body, number/nature of blows, conduct before and after attack) – Defence of property/self-defence – afterthought and excessive force.
3 December 2021
Appeal dismissed: procedural signature omission and lack of voire dire were not fatal; evidence and corroboration proved the applicant's guilt.
Criminal law – Grave sexual abuse – Elements: use of body part for sexual gratification and lack of consent; Evidence Act s.127 (post-2016) – child of tender years must promise to tell the truth; Criminal Procedure Act s.210(1)(a) – signing of proceedings; omission curable if authenticity and lack of prejudice shown; corroboration and admission as proof of guilt.
2 December 2021
Reporting alleged death threats amid a workplace dispute was reasonable, not malicious, so the applicants' malicious prosecution claim failed.
• Malicious prosecution – elements – malice as mala animus (ill-will) and requirement to prove improper motive; • Reasonable and probable cause – standard from Hicks v. Faulkner applied; • Employer liability for prosecution – need for evidence that employer instigated prosecution; • Criminal complaint by alleged victim – reporting to police may be reasonable amid credible threat or workplace intimidation.
2 December 2021
Court dismisses appeal: eyewitness identification under electric lighting was reliable; late alibi and arrest delay did not create reasonable doubt.
Criminal law – Armed robbery – Visual identification – Waziri Amani principles – requirements for watertight identification. Criminal procedure – Alibi raised late – sections 194(4),(5),(6) CPA – discretionary weight. Criminal procedure – Delay in arrest – effect on prosecution case. Evidence – Minor inconsistencies and typographical errors not material to conviction.
1 December 2021
Minor procedural defects did not vitiate the rape conviction; prosecution proved penetration and age; appeal dismissed.
Criminal procedure — section 210(3) Criminal Procedure Act — witnesses’ right to have recorded evidence read over; omission curable under section 388 where no prejudice shown. Criminal law — rape — essential elements: penetration and age of victim — victim’s testimony and medical report corroboration. Evidence — discrepancies and contradictions — assess whether they go to the root of the case; minor inconsistencies do not necessarily vitiate conviction. Defence — alibi — requirement to give prior notice under section 194(4) CPA and burden to establish alibi; failure to do so reduces its weight. Appellate review — duty to re-evaluate defence where lower courts failed to consider it; Court may step into appellate court’s shoes.
1 December 2021
November 2021
Child witness's evidence admitted without statutory promise was expunged; remaining evidence insufficient, conviction quashed and appellant acquitted.
Criminal law – sexual offences – evidence of child of tender age – non‑compliance with s.127(2) Evidence Act (failure to promise to tell the truth) – expungement of evidence; sufficiency of remaining evidence in sexual offences; appellate jurisdiction – inadmissibility of new factual grounds on second appeal.
30 November 2021
Credible child-victim evidence and corroboration upheld unnatural offence conviction despite excluded confession.
Criminal law – Unnatural offence – conviction based on child-victim’s testimony and corroboration Evidence – child witness competence and procedure (voir dire; promise-to-tell-truth amendment effective 8 July 2016) Evidence – cautioned statement admissibility and voluntariness inquiry Criminal procedure – pre-arraignment detention/production to court (section 32 CPA) Identification – failure to hold identification parade where witnesses knew accused Sentencing/judgment formalities – omission to restate statutory provisions curable under CPA
30 November 2021
Appellate court upheld incest conviction, finding victim's credible testimony and sufficient corroboration; appeal dismissed.
Criminal law – Sexual offences – Incest by male (Penal Code); victim's testimony as crucial evidence in sexual offences – applicability of section 127(6) Evidence Act and Selemani Makumba principle. Evidence – Corroboration by family witnesses and medical report; medical evidence admissible to show intercourse but not exact timing. Criminal procedure – Contents of judgment – compliance with section 312(1) CPA. Appeal – Second appeal limited to points of law; Court may reassess shortcomings of appellate review where necessary.
26 November 2021
A charge omitting the essential element of being armed in armed robbery is fatally defective and renders trial a nullity.
Criminal law – Armed robbery – Section 287A Penal Code – Essential ingredients include stealing, being armed, and use or threat of violence – charge must allege all ingredients. Criminal Procedure – Charge drafting – Sections 132 & 135 CPA – omission of material ingredient renders charge fatally defective. Evidence – Defect in charge cannot be cured where prosecution evidence does not establish omitted ingredient. Appeals – Second appellate court may decide point of law not addressed by first appellate court.
26 November 2021
Non-joinder of the Permanent Secretary rendered the appellant's suit unmaintainable; an executive agency is suable in its own name only in contract.
Civil procedure – Executive agencies – Tanzania Building Agency (TBA) suable in its own name only in contract – where no contract exists, Government Proceedings Act procedure applies and Ministry/Attorney General must be joined. Civil procedure – Joinder of parties – Necessary party (Permanent Secretary, Ministry of Works) must be joined where proprietary rights are affected and an effective decree cannot be passed otherwise. Remedy – Non-joinder of necessary government party renders suit unmaintainable; appropriate remedy can be setting aside proceedings and ordering retrial after joining necessary parties.
15 November 2021
Charge defects curable but material inconsistencies in prosecution evidence rendered rape conviction unsafe; appeal allowed.
Criminal law — Charge sheet defects — Non‑citation of subsection curable under s.388 CPA where particulars and evidence afford fair notice; Criminal procedure — s.312(2) CPA non‑compliance curable if no prejudice; Evidence — credibility of complainant in sexual offences, need for scrutiny where material inconsistencies and lack of corroboration render conviction unsafe.
2 November 2021
October 2021
A defective certificate of delay was held curable by rectification and filing a supplementary record under the overriding objective.
Commercial appeal — Certificate of delay — Rule 90(1) & (2) Court of Appeal Rules, 2009 — Defective certificate (format, incorrect dates, wrong aggregate days) — Consequences: rectification v striking out — Overriding objective (AJA ss 3A, 3B; Rule 2) — Supplementary record under Rule 96(7) to include correct certificate and missing trial evidence — Adjournment under Rule 38A(1).
1 October 2021
Conviction for rape quashed due to unreliable victim evidence and procedural failures, including unrecorded demeanour remarks.
Criminal law – Sexual offences – Sole evidence of the victim under section 127(6) Evidence Act – requires thorough scrutiny and not to be treated as gospel truth. Criminal procedure – Duty to record remarks on witness demeanour in proceedings (s.212 Criminal Procedure Act) – remarks cannot be first introduced in judgment. Appeals – Second appeals – Court will not entertain new grounds not argued and decided in first appeal; appellate court may re-evaluate evidence where lower courts failed to consider defence. Evidence – Delay in reporting, lack of medical/DNA tests and inconsistencies may undermine victim’s credibility in rape prosecutions.
1 October 2021
Recent possession sustained conviction despite weak visual identification; first appellate court failed to re-evaluate evidence.
Criminal law – armed robbery – doctrine of recent possession – elements: possession of stolen property, positive identification, recentness, subject matter of charge. Evidence – visual identification – need for careful scrutiny of observation time, distance and lighting; earliest opportunity to name suspect. Evidence – chain of custody – distinction between exhibits easily changable and durable items (motorcycle). Appeals – duty of first appellate court to re-evaluate trial evidence; higher court may step into its shoes where re-evaluation was not done.
1 October 2021
Appeal allowed where search warrant was not read and chain of custody for seized ammunition was broken, rendering the case unproven.
Criminal law – unlawful possession of ammunition – necessity of proving chain of custody for seized exhibits – unexplained gaps invalidate authenticity. Evidence – admissibility of documents – requirement to read a tendered exhibit in open court; failure amounts to improper admission. Criminal procedure – burden to prove exhibits’ custody and handover from seizure to tendering in court.
1 October 2021
Failure to explain vital legal issues to assessors vitiated their opinion; conviction quashed and retrial ordered.
Criminal procedure – Trials with assessors – Proper selection and opportunity to object to assessors – Duty to explain assessors’ role – Summing-up to assessors – Necessity to explain ingredients of offence, chain of custody and treatment of inconsistencies – Failure to do so vitiates assessors’ opinion and proceedings from summing-up to judgment – Remedy: nullification and retrial.
1 October 2021
Review granted: appellate omission to quash convictions after declaring proceedings nullity and inclusion of withdrawn appellant in retrial were corrected.
Criminal procedure – Appeal – Review under Rule 66(1)(a) & (b) and Rule 66(6) – manifest error on face of record – omission to nullify proceedings, quash convictions and set aside sentences after declaring trial nullity. Right to be heard – inclusion of appellant who had withdrawn appeal in retrial order – denial of fair hearing. Remedy – appellate modification under Rule 66(6) rather than full rehearing; release order where detention results from erroneous order. Adjournment of rehearing; parties to bear own costs.
1 October 2021
September 2021
Failure to properly select, brief or have assessors present and an inadequate summing up rendered the trial null and void; retrial ordered.
Criminal procedure – assessors: proper selection, notification to accused and explanation of role; summing up – requirement to summarise evidence and explain vital legal points to assessors; absence of assessor during evidence and later participation – fatal irregularity; cumulative irregularities render trial a nullity; remedy — quash conviction and order retrial.
30 September 2021
Denying bail without serving affidavit or hearing the accused violated the right to be heard; conviction quashed and retrial ordered.
Criminal procedure – Section 192 CPA – requirements and conduct of preliminary hearing; memorandum of undisputed facts. Constitutional and procedural right – Right to be heard; denial of bail based on affidavit not served and not on record vitiates proceedings. Criminal appeal – Nullity of proceedings and judgments arising from breach of right to be heard; quashing of conviction and ordering of retrial. Retrial – Application of Fatehali Manji principles; retrial appropriate where interest of justice so requires.
30 September 2021
Appeal struck out for failure to serve notice, memorandum and application for copies, making the appeal incompetent and time-barred.
Civil procedure – Appeal competence – mandatory service requirements under Rules 84(1), 97(1) and 90(3) of the Tanzania Court of Appeal Rules; non-service renders appeal incompetent and, where application for copies is not served, appeal becomes time-barred.
30 September 2021
Failure to hear a party on a court-raised issue vitiated the ruling; change of judge without recorded reasons was irregular but not fatal.
Civil procedure — Order XVIII r.10 CPC — Succession of judge — Duty to record reasons when taking over partly heard matters; applies to applications decided on affidavits and submissions. Natural justice — Audi alteram partem — Court raising and deciding issue suo motu (propriety of power of attorney) without affording party opportunity to be heard vitiates proceedings. Overriding objective — AJA ss.3A,3B — Curative effect where no material prejudice shown.
30 September 2021
The appeal was allowed because identification and cautioned-statement irregularities and failure to call material witnesses undermined the prosecution.
Criminal law – Identification evidence – need for prior detailed description and proper conduct/read-over of identification parade register; Cautioned statements – must be read over after admission or are of no evidential value; Failure to call material witnesses (ballistic expert and victim) – adverse inference; Conviction unsafe where key evidence expunged.
30 September 2021
The appellant's equivocal plea admitting presence, not transporting migrants, vitiated conviction; appeal allowed and remitted.
Criminal law – Plea of guilty – Requirement that plea be unequivocal and admit every ingredient of offence – Section 192 CPA preliminary hearing only for not guilty pleas – Section 360(1) CPA bar to appeals on guilty pleas and recognised exceptions – Conviction vitiated by equivocal plea – Remittal for trial as if not guilty.
29 September 2021
Conviction quashed where visual identification was unreliable and cautioned statement was recorded outside statutory time and inadmissible.
Criminal law — armed robbery; sufficiency of evidence. Visual identification — night-time incidents; need for detailed evidence on lighting, proximity and duration (Waziri Amani principles). Cautioned/confessional statement — statutory time-limits under s.50(1) Criminal Procedure Act; requirement to inform suspect of rights; non-compliance renders statement inadmissible. Conviction unsafe where identification and confession are both unreliable or inadmissible.
27 September 2021
April 2021
Failure to summon assessors on vital legal points vitiated the trial; conviction quashed and retrial refused for insufficient evidence.
Criminal procedure – trial with assessors – duty to sum up on all vital points of law (circumstantial evidence, doctrine of recent possession, ingredients of offence) – failure vitiates proceedings; Circumstantial evidence – identification and proof of ownership of exhibits – necessity of prior description and documentary links (e.g. phone registration) before relying on recent possession; Retrial – principles and when retrial should not be ordered.
30 April 2021
Inadequate summing up to assessors on identification and retracted confession vitiated the trial; retrial ordered.
Criminal procedure – duty of trial judge to sum up adequately to assessors on all vital points of law. Evidence – visual and voice identification made at night; conditions for relying on such identification. Evidence – cautioned/confession statement retracted by accused; evidential value and cautionary direction required. Appellate/revisional powers – nullification of proceedings where assessors not properly directed. Retrial – principles for ordering retrial (Fatehali Manji) and interest of justice.
30 April 2021
Failure to comply with reinstatement clause time limits converts measure of indemnity to market/value at date of loss.
Insurance law – contract of indemnity – reinstatement value clause – compliance with time/notice conditions – measure of indemnity (market value v. reinstatement) – burden of proof on insured – appellate reappraisal of evidence.
19 April 2021
March 2021
An extension to file an appeal was prematurely granted while a prior application to strike out the notice of appeal remained undecided.
Civil procedure – Extension of time to file appeal – Validity of notice of appeal – Pending application to strike out notice must be determined before granting extension; Reference – Full Court may interfere where single judge fails to consider material preliminary issue.
19 March 2021
February 2021
Failure to allow rejoinder on admissibility of exhibits breached the right to be heard and vitiated the trial, prompting retrial.
Civil procedure — admission of documents — objections, reply and rejoinder procedure — right to be heard (audi alteram partem) — breach vitiates proceedings — retrial ordered.
26 February 2021
Whether the certificate of delay and record of appeal complied with Rules 90 and 96, and whether defects are curable.
Civil procedure – Court of Appeal Rules, Rule 90(1): certificate of delay – computation must be from date of lodgement/receipt in High Court; certificate must state number of days to be excluded (Form L). Civil procedure – Court of Appeal Rules, Rule 96(3) & (7): completeness of record of appeal – Registrar’s power to exclude exhibits and remedy by filing supplementary record; omission of a document by filing only a notice does not properly include it in the record. Remedies – curable procedural irregularities: leave to file corrected certificate and supplementary record rather than striking out appeal.
25 February 2021
An ordinary civil suit is not a proper vehicle to challenge administrative decisions; appeal dismissed for want of jurisdiction and maintainability.
Administrative law — challenge to administrative acts — improper use of ordinary civil suit to question Government Notices and abolishment of villages; locus standi and jurisdiction — requirement to invoke proper forum (judicial review/ statutory procedure) — representative suit procedure (Order 1 r.8 CPC) — pleadings and maintainability.
25 February 2021
Inadequate summing up to assessors on vital legal points rendered the murder trial a nullity; retrial ordered.
Criminal procedure – Trial with assessors – Mandatory requirement under section 265 CPA – Adequacy of summing up to assessors; omission to direct assessors on ingredients of murder, circumstantial evidence, doctrine of recent possession, visual identification and accused’s conduct renders trial a nullity. Appellate jurisdiction – Exercise of revisional powers under section 4(2) – Quashing of proceedings and ordering of retrial.
25 February 2021
Stay of execution granted pending appeal: application timeous, substantial loss shown, third‑party security acceptable.
Civil procedure — Stay of execution (Rule 11) — requirements: timeous application; substantial/irreparable loss; adequate security — third‑party customary title and owner affidavit may suffice as security — conditional stay pending appeal.
25 February 2021
Appeal allowed: conviction quashed due to credibility doubts, material contradictions, and failure to consider defence evidence.
Criminal law – Incest – credibility of victim and delay in reporting; Evidence – contradictions between oral testimony and documentary evidence (guest register); Missing key witness — adverse inference; Criminal procedure – proper evaluation of defence and burden of proof; Appellate review of concurrent findings of fact.
24 February 2021
A court cannot raise and decide a new issue suo motu without first affording the parties a right to be heard.
Civil procedure — appellate practice — court raising new issue suo motu at judgment composing stage — vicarious liability — right to be heard and natural justice — decision in violation of hearing rights is a nullity — remittal for rehearing on new issue.
19 February 2021
Variance between charge particulars and evidence plus inadequate identification made recent-possession conviction unsafe; appeal allowed.
Criminal procedure – variance between charge particulars and evidence – duty to amend under section 234 Criminal Procedure Act; amendment required to meet case circumstances. Evidence – doctrine of recent possession – requirements: possession, positive identification by owner, recent theft, and property forming subject of charge. Evidence – identification of exhibits – owner should first identify distinctive marks before exhibits tendered. Evidence – chain of custody/certificate of seizure – relevance where seizure by civilians and police procedures involved. Appeals – second appeal limited to points of law but may interfere with concurrent findings where misapprehension of evidence causes miscarriage of justice.
19 February 2021
Variance in charge and broken chain of custody defeated prosecution; conviction quashed and sentence set aside.
Wildlife offences – unlawful possession of trophy – variance between charge and evidence – requirement to amend charge under s.234 Criminal Procedure Act; Chain of custody – failure to establish handling of exhibits; Perishable exhibits – need for magistrate's order before disposal (Police General Orders); Cautioned statement – where it does not confess, cannot sustain conviction.
19 February 2021
Five village members must be joined where the respondent’s pleadings and annexure named them as alleged interferers with his land.
Joinder of parties – Order 1 Rule 10(2) and Order 1 Rule 3 CPC – Cause of action to be ascertained from pleadings and annexures – Annexures part of pleadings – Public interest locus standi not applicable to joinder in ordinary civil suits – Necessary parties must be joined to enable complete adjudication and to avoid multiplicity of suits.
17 February 2021
An application cannot be withdrawn to pre-empt a preliminary objection; Court struck out the incompetent application with costs.
Civil procedure – Withdrawal of application – Preliminary objection as to competence – A preliminary objection must be heard before any withdrawal – Incompetent application cannot be withdrawn to pre-empt objection – Strike out with costs; Rule 58(1) Tanzania Court of Appeal Rules.
17 February 2021
Improperly admitted and unread documentary exhibits were expunged, collapsing the prosecution case and leading to quashing of conviction.
Criminal procedure – admission of documents: documents must be cleared for admission, actually admitted and read out; failure is fatal and warrants expungement; where expunged documents form the crux of the prosecution case, conviction must be quashed. Issues also raised: chain of custody of seized exhibits; competence to prepare trophy valuation under s.86(4) Wildlife Act.
16 February 2021
Appellant's WSD filed within seven days before hearing was timely; High Court's ex parte order quashed.
Civil procedure — summons to appear v. summons to file defence — interpretation of Order V r.1 and Order VIII r.1 CPC — time for filing written statement of defence — court cannot require filing outside statute — parties should not be punished for court errors — ex parte proof set aside.
12 February 2021
Victim’s credible testimony can sustain sexual‑offence conviction; procedural irregularities curable and did not vitiate conviction.
Criminal law – sexual offences – conviction on child‑victim’s uncorroborated evidence (s.127(7) Evidence Act); evidence – no duty to call specific witnesses (s.143 Evidence Act); procedure – non‑compliance with s.210(3) CPA curable under s.388; second appeal standard – interference only for misdirection/non‑direction.
12 February 2021