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.
42 judgments

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42 judgments
Citation
Judgment date
October 2021
Victim's sworn evidence and supporting circumstantial/medical evidence sufficed to prove rape beyond reasonable doubt.
Criminal law – Rape – proof of penetration – victim’s sworn evidence as best evidence; Evidence Act s.127 (child of tender age) distinction between minors and children under 14; Penal Code s.130(4)(a) slight penetration sufficient; medical evidence (absence of hymen/no bruises) not conclusive; amendment of charge under Criminal Procedure Act s.234(1); failure to call non-material witness – no adverse inference.
1 October 2021
Conviction quashed where identification was unreliable and cautioned statement was recorded outside the statutory four‑hour period.
Criminal law – Admissibility of cautioned statement – s.50(1)(a) CPA four‑hour rule; Identification of stranger – necessity of contemporaneous description to first recipient to avoid mistaken identity; Standard of proof – prosecution must prove identity beyond reasonable doubt; Sentencing – unnatural offence involving a child attracts life imprisonment under s.154(2) Penal Code.
1 October 2021
An applicant must show a point of law, not mere factual dispute, to obtain leave to appeal to the Court.
Leave to Appeal – requirement of a point of law; factual disputes (location of property) do not qualify as points of law; second bite under Rule 45(b); execution of Ward Tribunal decrees and competence of DLHT.
1 October 2021
Applicant failed to show good cause for extension to file notice of appeal and to apply for leave; application dismissed.
Extension of time – Rule 10 Court of Appeal Rules – requirement to show good cause; notice of appeal must be lodged before applying for leave (Rule 46(1)); distinction between technical and actual delay (Fortunatus Masha); illness, ignorance or negligence do not constitute good cause; illegality must be apparent on the face of the record (Lyamuya).
1 October 2021
Improperly admitted documentary exhibits expunged, but remaining evidence upheld convictions for armed robbery, rape and grievous harm.
Criminal law – identification evidence; documentary exhibits – requirement to admit and read out contents before reliance; expungement of improperly admitted exhibits; corroboration by medical evidence; elements of armed robbery (threat/use of weapon, theft).
1 October 2021
Leave granted to appeal on whether time to obtain a certified tribunal judgment copy is excludable from appeal limitation.
Land appeals – limitation – s.41(2) Land Disputes Courts Act – whether time spent procuring certified copy of tribunal judgment is excludable – requirement for leave – grant of leave to appeal.
1 October 2021
September 2021
Omission to swear witnesses and to sign their evidence at the CMA vitiated proceedings; matter remitted for de novo hearing.
Labour arbitration — administration of oath to witnesses mandatory — failure vitiates proceedings; arbitrator's signature on witness evidence — omission undermines authenticity and is fatal; award and subsequent High Court proceedings arising from a null arbitration are set aside and matter remitted for de novo hearing before another arbitrator.
30 September 2021
Victim's uncorroborated testimony and an extra‑judicial confession upheld the rape conviction despite expunged statements.
Criminal law – Rape – Victim’s testimony need not be corroborated; Evidence Act s.127(6); Criminal Procedure Act s.50(1)(a) – cautioned statements and statutory time limit; Admissibility of extra‑judicial/confessional statements recorded by a Justice of the Peace; Procedural omission by appellate court and prejudice test.
29 September 2021
Absence of DPP consent and certificate rendered the subordinate court's trial of an economic offence a nullity; conviction quashed.
* Criminal procedure – Jurisdiction – Economic offences triable by High Court – DPP’s consent and certificate required to confer jurisdiction on subordinate courts (sections 3, 26(1) and 12(3) of the Act). * Absence/non-receipt of DPP’s consent and certificate renders subordinate court proceedings a nullity; subsequent High Court proceedings founded on such trial are likewise null. * Revisional powers – quashing of proceedings and conviction; discretion against retrial where prosecutorial error would enable filling evidential gaps (Fatehali Manji principle).
29 September 2021
Unproved suspected narcotics must be chemically analysed; admissions about a substance's identity cannot substitute for testing.
Drugs Control Act – requirement to submit suspected narcotics/psychotropics to Government Chemist for analysis (s.67; Reg.21); Failure to test renders exhibit inadmissible; Cautioned statement admissions on substance identity lack evidential weight without chemical analysis.
28 September 2021
Conviction quashed where identification and possession were not proved beyond reasonable doubt due to evidential gaps.
* Criminal law – Identification evidence – opportunity to observe, naming at earliest opportunity and corroboration; failure to call key eyewitness affects credibility. * Criminal law – Possession and recovery – abandoned property found in bush is not conclusive proof of possession; village and police witnesses relevant. * Criminal procedure – Variance between charge and evidence – special (constructive) owner versus actual owner; minor/curable variances. * Appellate procedure – duty of appellate court to consider grounds presented; Court of Appeal may decide omitted grounds or remit where appropriate. * Evidence – family/business associates may testify but credibility must be tested; absence of phone/M-Pesa corroboration weakens identification.
28 September 2021
Inadequate summing up to assessors vitiated murder conviction; retrial refused due to reliance on a disputed cautioned statement.
Criminal appeal – assessors – duty of trial Judge to sum up adequately on vital points of law (circumstantial evidence) – omission vitiates proceedings; cautioned statement (exhibit) repudiated by accused – reliance thereon unsafe; retrial – Fatehali Manji principles – declined where prosecution case weak.
28 September 2021
Failure to serve the notice of appeal within 14 days renders the appeal incompetent and is struck out with costs.
* Civil procedure – Court of Appeal Rules, 2009 – Rule 84(1) mandatory requirement to serve notice of appeal within 14 days; non-compliance renders appeal incompetent. * Proof of service – absence of endorsement/signature on notice in record is fatal. * Preliminary objections – competence of appeal determined before merits; failure to comply with procedural rules attracts striking out with costs.
28 September 2021
Omission to administer oath and to sign witness testimony vitiates CMA proceedings and warrants quashing and retrial.
* Labour law — CMA procedure — mandatory oath/affirmation for witnesses — omission vitiates proceedings. * Evidence — signing of witness testimony — absence undermines authenticity of record and is fatal. * Appellate review — quashing and remittal for rehearing de novo where mandatory procedural safeguards were omitted.
24 September 2021
Failure to swear witnesses and absence of arbitrator's signature vitiated CMA proceedings; matter remitted for rehearing.
* Labour law – arbitration procedure – mandatory administration of oath to witnesses under G.N. No. 67 of 2007 (rule 25(1)) – failure vitiates proceedings. * Procedural requirement – arbitrator’s signature on recorded evidence – omission undermines authenticity and vitiates award. * Remedy – quash proceedings and remit for rehearing de novo before another arbitrator.
24 September 2021
Failure to properly sum up evidence and law to assessors vitiates trial, warranting retrial.
* Criminal procedure – trials with assessors – duty to sum up evidence and law to assessors; failure vitiates proceedings. * Evidence – caution statement (retracted) and post-mortem corroboration; issues of extrajudicial statement production. * Criminal law – defence of compulsion – requirement of imminent danger/grievous harm. * Remedy – nullification of proceedings and order for retrial de novo before another judge and new assessors.
23 September 2021
Procedural omissions were harmless and eyewitness identification in daylight upheld the rape conviction.
Criminal procedure — s.214 CPA: lawful transfer and continuation of trial; s.234(2) CPA: substitution of charge and failure to recall witnesses — harmless where amendment corrects penal provision and causes no prejudice; delay in charging — cannot be raised for first time on appeal; identification evidence — previous acquaintance and daylight identification reliable; rape — corroborative medical and eyewitness evidence sufficient.
23 September 2021
A claimant lacking legal interest in land has no locus standi to sue, and proceedings must be quashed.
Land law – Locus standi – Claimant must have legal interest in land to sue; locus standi is jurisdictional and may be considered at any stage – Adverse possession not reached where claimant lacks locus standi – Ward Tribunal erred in entertaining claim by a person without title.
23 September 2021
Failure to direct assessors on alibi and repudiated confessions vitiated the trial; retrial ordered.
* Criminal procedure – assessors – duty of trial Judge to sum up adequately on all vital points of law; failure is fatal. * Criminal evidence – repudiated confessions – nature and conditions in which cautioned and extra-judicial statements may be acted upon. * Defence of alibi – duty to direct assessors on its nature and application. * Remedy – omission to direct assessors vitiates trial; ordinarily retrial de novo ordered, though limited cases permit only fresh summing-up.
21 September 2021
The appellant's conviction was quashed due to unexplained reporting delay and doubtful corroborative evidence.
Criminal law – rape of a child; evidence – best evidence principle (s.127(6) Evidence Act); corroboration – circumstantial support by secondary witness; documentary evidence – PF3 inadmissible if not read over; delay in reporting – effect on credibility; medical evidence – timing and probative value; benefit of doubt – acquittal where prosecution fails to exclude reasonable doubt.
21 September 2021
Conviction based on recent possession quashed because prosecution failed to prove the stolen phone belonged to the complainant.
Criminal law — Armed robbery — Doctrine of recent possession — Essential requirement to prove recovered property belonged to the complainant (identifying marks/serial numbers or receipt) — Failure to prove identity defeats recent-possession-based conviction.
20 September 2021
Failure to administer oaths and to sign witness testimonies vitiated CMA proceedings, warranting quashment and rehearing.
Labour law — CMA procedure — mandatory administration of oath to witnesses (Rule 25(1) GN No. 67/2007; Oaths and Statutory Declarations Act); requirement for arbitrator's signature to authenticate witness evidence; omissions vitiate proceedings — quashment and remittal for retrial.
20 September 2021
June 2021
Retracted cautioned confessions admissible if judicially warned and corroborated; JP-recorded confession vitiated for non‑compliance.
Criminal law – Murder – Reliance on retracted cautioned statements – Trial judge must warn herself of dangers and be satisfied of truth; extra-judicial statements by Justices of the Peace must comply with Chief Justice's Instructions; corroboration by independent evidence and autopsy may validate retracted confessions.
21 June 2021
May 2021
Clarificatory questions by assessors do not vitiate proceedings; fatal stabbing during a fight amounted to manslaughter, not murder.
• Criminal law – role of assessors – assessors may ask questions for clarification under section 177 Evidence Act but must not cross-examine as adverse parties. • Criminal law – murder v. manslaughter – death occurring in the course of a fight is manslaughter absent malice aforethought. • Procedure – prejudice required to invalidate proceedings where assessors question witnesses.
7 May 2021
An action brought in the name of an unincorporated trust by an unauthorized person renders proceedings a nullity.
* Trustees Incorporation Act – corporate status – requirement to sue and be sued in the corporate name including "Registered Trustees"; * Locus standi – who may institute proceedings for a registered trustees' body; * Authority of representatives – persons authorised to sue for a body corporate; * Procedural defect – misnomer/unauthorised institution of suit may render proceedings a nullity.
7 May 2021
Court of Appeal lacks jurisdiction to entertain second‑bite leave application where High Court refused leave under pre‑2018 law.
Land law — Leave to appeal — Exclusivity of High Court jurisdiction under pre‑2018 section 47 Cap. 216 — Second‑bite applications under Rule 45(b) — 2018 amendment to section 47 and non‑retrospectivity — Remedy: extension of time under section 11 Appellate Jurisdiction Act.
7 May 2021
Employer failed to prove valid reason and fair procedure for termination; appeal dismissed and award upheld.
Labour law – unfair termination – employer's burden under s.37(2) ELRA to prove valid/fair reason and procedure – procedural fairness – Rule 13(2) (service of charge) – admissibility and opportunity to tender medical evidence.
6 May 2021
Search and seizure irregularities and unreliable witness evidence vitiated conviction for possession of government trophies.
* Criminal procedure – committal proceedings – partial non‑compliance with Rule 8(3) GN. No.267 of 2016 – not always fatal if accused later afforded full opportunity to defend. * Search and seizure – Police Form No.91 (PF91) – material contradictions, missing/irregular signatures and unexplained anomalies vitiate exhibit. * Evidence – failure to call key witnesses and unreliable independent witness entitles court to draw adverse inference. * Applicability – searches under CPA require compliance with section 38(1) and (3); Wildlife Act provision on independent witnesses for dwelling searches is not a substitute when CPA procedure is used. * Standard of proof – where admissibility and authenticity of seizure form is excluded, prosecution fails to prove possession beyond reasonable doubt.
5 May 2021
Victim's credible testimony and medical evidence upheld convictions; illegal sub‑minimum sentences corrected to statutory penalties.
Criminal law – rape and unnatural offence on a child; victim's testimony as primary evidence; medical report corroboration; admissibility and credibility of investigating officer's evidence; no legal requirement for DNA/STD evidence; procedural compliance with trial recommencement; correction of illegal sentences to statutory minima.
4 May 2021
Appellant failed to prove gift inter vivos or ownership; adverse possession unpleaded; appeal dismissed with costs.
* Land law – ownership – gift inter vivos – burden of proof and preponderance of probabilities; credibility of witnesses. * Pleadings – party bound by pleadings; adverse possession cannot be raised without pleading. * Family land – disposition by beneficiary and locus standi to sell – requirement for direct evidence of sale.
4 May 2021
Extension of time granted because non-joinder and denial of hearing constituted apparent illegality affecting applicant's title.
* Civil procedure – Extension of time under Rule 10 – discretion exercised where good cause shown; * Requirement to account for every day of delay, but unexplained delay may be excused where apparent illegality exists; * Jurisdiction/illegality – non-joinder and denial of hearing in proceedings affecting proprietary rights constitutes apparent illegality and may render judgment a nullity; * Revision as appropriate remedy where aggrieved person was not a party to earlier proceedings affecting their rights.
3 May 2021
Failure to properly direct assessors on circumstantial evidence voids the trial and mandates a retrial.
Criminal procedure – Trials with assessors – Duty to sum up – Circumstantial evidence must be fully explained to assessors; omission is fatal. Sections 265, 298 Criminal Procedure Act; retrial ordered.
3 May 2021
Child’s unsworn testimony, properly received and corroborated, upheld conviction for grave sexual abuse; appeal dismissed.
Criminal law – sexual offence (grave sexual abuse) – child witnesses – Evidence Act s.127 (unsworn evidence, promise to tell truth, corroboration) – presence of social welfare officer required only in Juvenile Court proceedings – mitigation procedure – sufficiency of evidence.
3 May 2021
The applicant’s uncorroborated claim of a lost review filing and lack of arguable review grounds warranted dismissal.
Criminal procedure — extension of time under Rule 10 — requirement to show good cause and account for each day of delay; must demonstrate an arguable review case under Rule 66(1); review distinct from appeal — factual complaints are not review grounds; uncorroborated claims of a lost filing are insufficient evidence.
3 May 2021
Failure to direct assessors on malice, alibi and provocation rendered the trial a nullity; conviction quashed and retrial ordered.
Criminal procedure – summing up to assessors – section 298(1) CPA – failure to direct assessors on malice aforethought, alibi and provocation renders trial a nullity; conviction quashed; retrial ordered; appellant remanded pending retrial.
3 May 2021
April 2021
Failure to serve the written request for High Court copies under Rule 90(3) prevents reliance on delay exception, rendering the appeal time‑barred.
Civil procedure — Appeal time limits — Rule 90(1) and (3), Tanzania Court of Appeal Rules — Written application for copies must be served on respondents — Non‑compliance bars reliance on Registrar’s certificate of delay — Appeal filed out of time — Struck out.
30 April 2021
A credible child‑victim’s testimony under section 127(7) can alone sustain conviction if the court records reasons.
* Evidence – Sexual offences – Section 127(7) Evidence Act – Child‑victim (tender years) testimony may suffice without corroboration if court records credibility reasons. * Evidence – Corroboration – Playmate and medical evidence can support victim’s testimony. * Criminal procedure – Alibi defence – Notice requirement under section 194(4) – failure to give notice renders alibi weak. * Appellate practice – Second appeals limited to grounds raised in first appellate court; new grounds not entertainable. * Preliminary hearing – Calling witness not listed at preliminary hearing is permissible.
30 April 2021
High Court's sua motu decision without hearing violated right to be heard; ruling and subsequent review nullified.
Natural justice – right to be heard – court raising and deciding point of law suo motu without hearing parties – decision nullity; competence of applications based on enabling provisions; review of High Court rulings; amendment of section 47 LDCA removing leave requirement in land matters.
30 April 2021
Victim's testimony and medical report proved statutory rape; concurrent factual findings upheld and appeal dismissed.
* Criminal law – Sexual offences – Statutory rape under section 130(2)(e) – proof of victim's age – medical report admissible to establish age. * Evidence Act s.127 – victim's testimony in sexual offences can suffice to prove penetration; corroboration not always required. * Appellate procedure – scope of second appeal – concurrent findings of fact will not be disturbed absent demonstrable error, misdirection or miscarriage of justice. * Credibility – inconsistent defence statements undermine accused's account.
30 April 2021
A plea of "Ni kweli" with unreserved factual admissions constituted an unequivocal guilty plea; appeal dismissed.
* Criminal procedure – plea of guilty – whether utterance "Ni kweli" constitutes an unequivocal plea. * Criminal procedure – s.360(1) CPA – general bar to appeals on guilty pleas and recognized exceptions (Laurence Mpinga criteria). * Evidence – admission of facts and exhibits (cautioned and extrajudicial statements) as basis for conviction on plea. * Substantive law – elements of armed robbery (theft, weapon, threat to use violence).
29 April 2021
Court upheld convictions for possession and attempted dealing in government trophies; valuation certificate rejected but convictions sustained.
Wildlife Conservation Act – unlawful possession and dealing in government trophies – evidence sufficiency – search and seizure in remote area without independent witness – competence and admissibility of trophy valuation certificate – valuation under Regulations – burden and statutory presumptions (ss.86,100,106,114 WCA).
29 April 2021
Where a trial record is missing, the originating Deputy Registrar must trace or reconstruct it to preserve the appellant's right to appeal.
* Criminal procedure — Missing or destroyed trial record — Registrar’s duty under Rule 71 to prepare and, where necessary, reconstruct the record. * Right to appeal and fair hearing — Article 13(6)(a) — requirement that appellate record be adequate for proper consideration. * Reconstruction of records — coordinated, exhaustive searches involving DPP, police, prison, National Archives and registries. * Procedural direction — Deputy Registrar (originating registry) to prepare record within 60 days; if irretrievable, to reconstruct with stakeholders.
28 April 2021